LUCIUS v. FABIANA FILIPPI RETAIL MIAMI LLC

• product images are announced but they do not have accessible labels. Screen reader users will hear and navigate through each image, but they only hear a long string of characters followed by "unlabeled graphic."
• 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. It also includes additional cart information and links to proceed to the shopping cart, however, neither the dialog nor the content is announced. 
• Filter options on the category page are not accessible for keyboard-only users.
• Skip functionality is not shown or announced on this website.
• The submenu content items are actionable elements, but they are not in tab index. Screen reader users do not hear these sub menu items. Users navigated the menu links and the sub menu was skipped but it did open immediately when users hovered over it with a mouse.
• The time selection drop-down does not have a label. Screen reader users only hear that a combo box is available. A popup is shown when a user clicks on the "Size Guide" link with the size information. Screen reader users can access the pop-up, but only the two headings are announced. Users cannot navigate to or hear the content in the chart itself. The labels for the size options are unclear when announced to the user. Only “clickable” is announced with the visible number, providing no context that these are the size options.
• When users submit the appointment form with an invalid email address an error message is displayed, but the error message is not announced by the screen reader tool.

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.