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Accessibility.com, LLC

COOKS v. NATURE REPUBLIC INTERNATIONAL, LLC

Filed February 3, 2020

Plaintiff

  • Name: Richard Cooks
  • Filing date: February 3, 2020
  • State of filing: California

Defendant

  • Name: Nature Republic International, LLC
  • Website: www.naturerepublicusa.com
  • Industry: Beauty
  • Summary: Nature Republic manufactures and sells all-natural beauty products, lotions, sunscreens, creams, sanitizers, and related products. 

Case Summary

On February 3, 2020, Richard Cooks filed a Complaint in California Federal court against Nature Republic International, LLC. Plaintiff Richard Cooks alleges that www.naturerepublicusa.com is not accessible per the WCAG 2.1 accessibility standard(s).

Case Details

Plaintiff alleges issues in its Complaint including the following:

  • Many features on the Website lacks alt. text, which is the invisible code embedded beneath a graphical image.
  • Many features on the Website also fail to Add a label element or title attribute for each field. This is a problem for the visually impaired because the screen reader fails to communicate the purpose of the page element. It also leads to the user not being able to understand what he or she is expected to insert into the subject field.
  • The Website also contains a host of broken links, which is a hyperlink to a nonexistent or empty webpage. For the visually impaired this is especially paralyzing due to the inability to navigate or otherwise determine where one is on the website once a broken link is encountered.
  • The Website does not provide a text equivalent for every non-text element;
  • The purpose of each link cannot be determined from the link text alone or from the link text and its programmatically determined link context;
  • Web pages lack titles that describe their topic or purpose;
  • Headings and labels do not describe topic or purpose;
  • Keyboard user interfaces lack a mode of operation where the keyboard focus indicator is visible;
  • The default human language of each web page cannot be programmatically determined;
  • Labels or instructions are not always provided when content requires user input;
  • Text cannot be resized up to 200 percent without assistive technology so that it may still be viewed without loss of content or functionality;
  • A mechanism is not always available to bypass blocks of content that are repeated on multiple web pages;
  • A correct reading sequence is not provided on pages where the sequence in which content is presented affects its meaning;
  • In content implemented using markup languages, elements do not always have complete start and end tags, are not nested according to their specifications, may contain duplicate attributes, and IDs are not always unique; and
  • The name and role of all UI elements cannot be programmatically determined; things that can be set by the user cannot be programmatically set; and/or notification of changes to these items is not available to user agents, including assistive technology.

Plaintiff asserts the following cause(s) of action in its Complaint:

  • Americans with Disabilities Act, 42 U.S.C. § 12181 et seq. 
  • Unruh Civil Rights Act, California Civil Code § 51 et seq.
  • Declaratory Relief

Plaintiff seeks the following relief by way of its Complaint:

  • A Declaratory Judgment that at the commencement of this action Nature Republic was in violation of the specific requirements of Title III of the ADA described above, and the relevant implementing regulations of the ADA, in that Nature Republic took no action that was reasonably calculated to ensure that its Website is fully accessible to, and independently usable by, individuals with visual disabilities;
  • A preliminary and permanent injunction pursuant to 42 U.S.C. § 12188(a)(1) and (2) and section 52.1 of the California Civil Code enjoining Defendant from violating the Unruh Civil Rights Act and ADA and requiring Defendant to take the steps necessary to make its website readily accessible to and usable by visually-impaired individuals; An award of costs and expenses of this action;
  • An award of statutory minimum damages of $4,000 per offense per person pursuant to section 52(a) of the California Civil Code.
  • For attorneys’ fees and expenses pursuant to California Civil Code §§ 52(a), 52.1(h), and 42 U.S.C. § 12205; An order certifying the Class under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel; and
  • Such other and further relief as this Court deems just and proper.

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