LUCIUS v. BRIONI AMERICA, INC.

• Numerous portions of the website do not interface with and are not readable by SRS. More specifically, features of the website that are inaccessible to the visually impaired include, but are not limited to, the following:
• the color element shown on the product page is not announced. For the Natural Cashmere Jumper page and after the Size field, focus skips the color element and jumps to the Add to Shopping Bag button. The website displays a dialog after an item is successfully added to the cart. The dialog contains a message informing users that the item was successfully added and includes additional cart information and links to view the shopping bag, however, neither the dialog or nor the content in it are announced.
• The Color, Size and Category buttons at the top of the Essential Wardrobe page do not receive focus and are not announced.
• The Search field in the header of the website is announced to screen reader users three times. After the third announcement, Tab key navigation no longer works in neither Firefox nor Chrome. Users are unable to use Tab to move forward once this element has been accessed.
• Screen reader users are not notified when form errors are present. After submitting the Book Your Appointment form, errors appear in red text, but are not announced.
• The remove cart item button is not labeled and just announced as "button."
• The date field is a required field in the Book Your Appointment form, but it is not operable for screen reader users which prevents them from making an appointment. The field is announced but screen reader users are unable to navigate to or select a specific date.

VIOLATION OF TITLE III OF THE AMERICANS WITH DISABILITIES ACT

• The Court issue a declaratory judgment that determines that the defendant's website at the commencement of the subject lawsuit is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• the court issue a declaratory judgment that determines that the defendant's website is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• The Court issue a Declaratory Judgment that Defendant has violated the ADA by failing to monitor and maintain its website to ensure that it is readily accessible to and usable by persons with vision impairment
• That this Court issue an Order directing Defendant to alter its website to make it accessible to, and useable by, individuals with disabilities to the full extent required by Title III of the ADA
• That this Court enter an Order directing Defendant to evaluate and neutralize its policies and procedures towards persons with disabilities for such reasonable time so as to allow Defendant to undertake and complete corrective procedures
• That this Court enter an Order directing Defendant to continually update and maintain its website to ensure that it remains fully accessible to and usable by visually impaired individuals
• An award of attorney’s fees, costs and litigation expenses pursuant to 42 U.S.C. § 12205
• Such other relief as the Court deems just and proper, and/or is allowable under Title III of the Americans with Disabilities Act.