RENDON v. VERNON COOMBS C

• ARIA attributes must conform to valid values, which presents a problem as failure to comply with allowed values results in content that is not accessible to assistive technology users;
• 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;
• ID attribute value must be unique, which is important as the ID attribute uniquely identifies focusable elements on a page. It does not make sense to duplicate an active ID. Duplicative active ID values break the accessibility of focusable elements
  including labels for forms, table header cells, etc., Screen readers and client-side scripts will skip any duplication other than the first instance. Validating HTML files helps prevent and eliminate possible sources of accessibility problems, when not breaking accessibility;
• IDs used in ARIA labels must be unique. This is important because duplicate ARIA IDs are common validation errors that may break the accessibility of labels, e.g., form fields, table header cells. Unique ID’s differentiate each element from another and prevent invalid markup, wherein only the first instant gets acted upon by client-side scripting, or where assistive technologies typically only reference the first one accurately;
• 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;
• 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;
• Select element must have an accessible name. When labels for form elements are absent, screen reader users do not know the input data expectations. Screen readers cannot programmatically determine information about input objects without an established label relationship (or redundant text serving as a label); and (8) Form <input> elements must have labels. When labels for form elements are absent, screen reader users do not know the input data expectations. Screen readers cannot programmatically determine information about input objects without an established label relationship (or redundant text serving as a label). The absence of labels prevent fields from receiving focus when read by screen readers, and users with impaired motor control do not get the benefit of a larger clickable area for the control since clicking the label activates the control

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.