Plaintiff
- Name: Andrew Zhang
- Filing Date: September 30, 2026
- Court: United States District Court Southern District of New York
- State: New York
- Attorney Firm: Usher Law Group, P.C.
Defendant
- Name: Stand Out For Good, Inc.
- Website: www.altardstate.com
- Industry: Retailing
- Standards Cited: WCAG 2.1 Level AA
- Summary: Operates an online retail platform offering clothing and accessories to consumers.
Case Summary
According to the complaint, Andrew Zhang, a visually impaired individual, is suing Stand Out For Good, Inc. for violating the Americans with Disabilities Act (ADA) due to the inaccessibility of its website, https://www.altardstate.com/. The plaintiff alleges that he faced numerous barriers while attempting to access the site, including unlabeled buttons and inaccessible menus, which prevented him from completing a purchase. Zhang seeks injunctive relief to ensure the website complies with ADA standards, as well as damages for emotional distress. The complaint also cites violations of the New York City and State Human Rights Laws.
Causes of Action
- VIOLATION OF TITLE III OF THE ADA
- VIOLATION OF THE NEW YORK CITY HUMAN RIGHTS LAW (NYCHRL)
- VIOLATION OF THE NEW YORK STATE HUMAN RIGHTS LAW (NYSHRL)
Key Allegations
- Defendant's website is inaccessible to individuals with visual impairments.
- Plaintiff encountered barriers such as unlabeled buttons and inaccessible menus.
- Defendant failed to comply with WCAG 2.1 Level AA accessibility standards.
Requested Relief
- Injunction requiring compliance with ADA accessibility standards.
- Damages for emotional distress and frustration caused by discrimination.
- Reasonable attorneys' fees and costs.
Jurisdiction & Venue
This Court has subject matter jurisdiction under 28 U.S.C. § 1331 and supplemental jurisdiction under 28 U.S.C. § 1367.

