RENDON v. EIGHTY TWENTY LLC

• Ensure that links with the same accessible name serve a similar purpose. This is important because the intention is to help users understand the purpose of each link in the content, so they can decide whether they want to follow it. Best practice is that links with the same destination would have the same descriptions but links with different purposes and destinations would have different descriptions
  which calls for consistency in identifying components that have the same functionality. Because the purpose of a link can be identified from its link text, links can be understood they are out of context, such as when the user agent providers a list of all the links on a page;
• Images must have alternate text. Screen readers have no way of translating an image into words that get read to the user, even if the image only consists of text. As a result, it’s necessary for images to have short descriptive alt text
  so screen reader users clearly understand the image’s contents and purpose. When you do not provide
  an acceptable alternative that works for their available sensory modalities, such as making an image
  accessible by providing a digital text description, screen readers cannot convert it into speech or braille
  to make it available by sound or touch;
• Aria-hidden elements do not contain focusable elements,
  which presents a problem because using the aria-hidden="true" attribute on an element removes the
  element and ALL of its child nodes from the accessibility API making it completely inaccessible to readers and other assistive technologies. Aria-hidden may be used with extreme caution to hide visibly rendered content from assistive technologies only if the act of hiding this content is intended to improve the experience for users of assistive technologies by removing redundant or extraneous
  content. If aria-hidden is used to hide visible content from screen readers, the identical or equivalent
  meaning and functionality must be exposed to assistive technologies; and 
• Text elements must have sufficient color contrast against the background, which presents a problem because Some people with low vision experience low contrast, meaning that there aren't very many bright or dark areas. Everything tends to appear about the same brightness, which makes it hard to distinguish outlines, borders, edges, and details. Text that is too close in luminance (brightness) to the background can be
  hard to read. There are nearly three times more individuals with low vision than those with total blindness. One in twelve people cannot see the average full spectrum of colors - about 8% of men and 0.4% of women in the US. A person with low vision or color blindness is unable to distinguish text
  against a background without sufficient contrast

Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.

• For a judgment that Defendant violated Plaintiff’s rights under the Unruh Civil Rights Act, California Civil Code § 51 et seq.
• For a preliminary and permanent injunction requiring Defendant to take the steps necessary to make the Website readily accessible to and usable by visually impaired individuals; but Plaintiff hereby expressly limits the injunctive relief to require that Defendant expend no more $20,000 as the cost of injunctive relief
• An award of statutory minimum damages of $4,000 per violation pursuant to section 52(a) of the California Civil Code; however, Plaintiff expressly limits the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
• For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, California Civil Code § 52(a); however, Plaintiff expressly limits the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
• For pre-judgment interest to the extent permitted by law
• For costs of suit
• For such other and further relief as the Court deems just and proper.