LUCIUS v. JASON OF BEVERLY HILLS FLORIDA, LLC

• 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:
• There are over 100 watches on a page of the website, each with different styles, bands, colors, and diamonds but all of the watches are announced with the same exact label so users cannot tell which product they're on.
• Every watch image on this page is announced as "The Dumanis Spartan Heading Level 2 Link" and none of the
  visual cues are announced so screen reader users just hear the same label announced approximately 113 times.
• The website is hard to navigate for screen reader users since they are unable to access submenu items, a search feature is not available, and skip navigation is not available. Also, only 3
  of the menu items are announced (Locations, Bespoke, Bridal) and a footer is not present so it's unclear how a screen reader user can shop in the Ladies, Men’s, or Timepieces sections.
• Users are not notified when errors are made during checkout.
• The website changes the field labels to red to indicate an error but this is not announced.
• The State field does not have an accessible label. It is announced as "combo box collapsed" and hint text is not present.
• Videos show users how different jewelry is made such as an engagement ring and bracelet, but there is no audio description available for these videos which will prevent some users from learning how certain products are made.
• The billing detail form shown during checkout does display error suggestions in text but they are not announced to screen reader users. The text is above the form and users cannot navigate to the suggestions to hear them.

Title III of the ADA, 42 U.S.C. § 12181 et seq.

• The Court issue a DeclaratoryJudgment that determinesthat 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.
• TheCourt issue a Declaratory Judgment that determines that theDefendant'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.