LUCIUS v. OASIS GARDEN, 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:
• sale prices are differentiated visually but are not announced to screen reader users. For example, the "10 Inch In-Line Fan 760 CFM" has two prices displayed. The second price is in grey with a strikethrough to indicate this is the original price.
• Screen reader users hear both prices announced without any indication of the sale amount, so it sounds as though a price range is being announced as opposed to a sale.
• The discount field is announced as a button. When activated, the button changes to a field onscreen and shows hint text which reads "Discount code or gift card" but this is not announced to screen reader users. After pushing the discount button, they do not hear anything. If they press the Tab key, then focus skips over the newly displayed promo field and takes users to the Pay Now button so screen reader users are not aware it is present.
• Skip navigation is not announced or displayed.
• The Account icon is not labeled. It is announced only as "Semi expanded link."
• The Quantity field label is only available in text onscreen, it is not announced to screen reader users.
• A submit mechanism is not announced for the Search field located at the top of the page. Sighted users can see a button with the image of a question mark, but screen reader users only hear "button.
• The cart label is not accurate. The label is announced as "void left parens right parens."

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.