LUCIUS v. LASERAWAY, LLC

• The 65% off popup includes a four-step form.
• After completing all steps and pressing Enter on the Get More Info button, the website displays a status message that reads "loading babe" followed by the percent loaded. After which, users are taken to a new webpage without notice. The status message is not announced and when users are taken to a new page, they don't hear the information about the offer. Instead, they must navigate a new webpage, starting from the Skip Nav function, and no additional information about the offer is on the page that users were directed to.
• After selecting a value in the Service quiz, the specific value turns red to confirm the item was selected but nothing is announced to screen reader users. The result is that users do not hear that a selection was made, or even which item was selected.
• The Skip to Main Content function is announced and displayed, however, it doesn't work. Users should be taken directly to the main content of the page, but nothing happens. A user must still navigate through the menu items.
• The Cart icon is announced as "clickable zero link" which does not inform users that they are on the Cart icon. A cart confirmation popup is displayed to show users that they successfully added an item to their bag but this window is not announced to screen reader users nor does it receive focus immediately, so screen reader users are not aware of it.
• Error suggestions are not descriptive enough for blind users. Users will hear that a field has been left blank, but they won't hear which field is blank. Ex, A screen reader users only hears "please fill out this field" when a field is left blank.
• A popup is shown over the field to show sighted users where the issue is, but this is not communicated to blind users

Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.

• The Court issue a Declaratory Judgment 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 determinesthat 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.