Erika Randolph v. BB BEAUTY LLC

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing BB Beauty LLC for failing to make their website, Fragranceusa.com, accessible to blind users. The complaint alleges that the website contains significant barriers that prevent blind individuals from completing transactions, violating the Americans with Disabilities Act (ADA). Randolph claims that despite her attempts to purchase a perfume, she faced numerous accessibility issues, including inadequate alt-text and reliance on a mouse for navigation. The plaintiffs seek a permanent injunction to require BB Beauty to make their website accessible and compensatory damages for the discrimination faced by blind users.

Causes of Action

• Violation of 42 U.S.C. §§ 12181 et seq. – Title III of the Americans with Disabilities Act
• Declaratory Relief
• Negligent Infliction of Emotional Distress

Key Allegations

• Defendant's website is not accessible to blind and visually-impaired persons.
• Plaintiff encountered multiple accessibility barriers on Fragranceusa.com.
• Defendant has failed to take steps to remedy the accessibility issues.

Requested Relief

• Preliminary and permanent injunction to prohibit Defendant from violating the ADA.
• Injunction requiring Defendant to make its website accessible to blind individuals.
• Payment of nominal damages.
• Compensatory damages in an amount to be determined at trial.

Proposed Class

all legally blind individuals in the United States who have attempted to access Fragranceusa.com and as a result have been denied access to the enjoyment of goods and services offered by Fragranceusa.com, during the relevant statutory period.

Jurisdiction & Venue

This Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182; venue is proper under 28 U.S.C. §1391(b)(1) and (2).