JAHODA v. PRETTYLITTLETHING.COM USA, INC.

• The Website and Apps prevent screen reader users who navigate sequentially through content from accessing primary content directly. 
• The Website and Apps do not provide sufficient text equivalents for important nontext elements. Providing text alternatives allows information to be rendered in a variety of ways by a variety of shoppers. 
• The Website and Apps provide a Size Guide that shoppers may
  review to determine what size apparel to purchase. Size guides
  are particularly important to consumers who shop online
  because they lack the opportunity to try on apparel,
  like the clothing that Defendants sell, before purchasing. Unfortunately, Defendants’ Websites and Apps do not provide
  alternative text to describe this sizing information to Plaintiff and other screen reader users sufficiently. Instead, screen readers read each character without context, putting the burden on Plaintiff to map which numbers associate with each size and international market. 
• Shoppers who perceive content visually will recognize the “decrease quantity” and “increase quantity” buttons on the www.prettylittlething.us website and understand from their visual context that by clicking them, Defendants will decrease and increase the size of their order accordingly. Unfortunately, Plaintiff cannot access, or click, these buttons with his screen reader, thereby blocking him from using this important
  shopping tool independently, which Defendants otherwise make
  available to shoppers who do not rely on screen reader technology to shop in its online stores.
• The Website and Apps uses visual cues to convey content and other information to sighted users. 
• Links and buttons on the Website and Apps do not describe their purpose.

Americans with Disabilities Act, 42 U.S.C. § 12181 et seq. 

• A Declaratory Judgment that at the commencement of this action Defendants were in violation of the specific requirements of Title III of the ADA described above, and the relevant
  implementing regulations of the ADA, in that Defendants took no action that was reasonably calculated to ensure that its Website and Apps are fully accessible to, and independently usable by, individuals with visual disabilities;
• A permanent injunction pursuant to 42 U.S.C. § 12188(a)(2) and 28 CFR § 36.504(a) which directs Defendants to take all steps necessary to bring its Website an Apps into full compliance with the requirements set forth in the ADA, and its implementing regulations, so that its Website and Apps are fully accessible to, and independently usable by, blind individuals, and which further directs that the Court shall retain jurisdiction for a period to be determined to ensure that Defendants have adopted and is following an institutional policy that will in fact cause it to remain fully in compliance with the law—the specific injunctive relief requested by Plaintiff is described more fully in paragraph 11 above.
• Payment of actual, statutory, and other damages, as the Court deems proper;
• Payment of costs of suit;
• Payment of reasonable attorneys’ fees, pursuant to 42 U.S.C. § 12205 and 28 CFR § 36.505, including costs of monitoring Defendant’s compliance with the judgment (see Gniewkowski v. Lettuce Entertain You Enterprises, Inc., Case No. 2:16-cv-01898-AJS (W.D. Pa. Jan. 11, 2018) (ECF 191); see also Access Now, Inc. v. Lax World, LLC, No. 1:17-cv-10976-DJC (D. Mass. Apr. 17, 2018) (ECF 11);
• Whatever other relief the Court deems just, equitable and appropriate; and
• An Order retaining jurisdiction over this case until Defendant has complied with the Court’s Orders.