- Name: Angel Rodriguez
- Filing date: September 10, 2020
- State of filing: New York
- Name: Impossible Foods Inc.
- Website: www.impossiblefoods.com
- Industry: Food Products
- Summary: Impossible Foods Inc. is a company that develops plant-based substitutes for meat products.
On September 10, 2020, Angel Rodriguez filed a Complaint in New York Federal court against Impossible Foods Inc. . Plaintiff Angel Rodriguez alleges that www.impossiblefoods.com is not accessible per the WCAG 2.1 accessibility standard(s).
Plaintiff alleges issues in its Complaint including the following:
- lack of alt-text on graphics
- inaccessible drop-down menus
- lack of navigation links
- lack of adequate prompting and labeling
- the denial of keyboard access
- empty links that contain no text
- redundant links where adjacent links go to the same URL address
- the requirement that transactions be performed solely with a mouse
Plaintiff asserts the following cause(s) of action in its Complaint:
- Violation of 42 U.S.C. §§ 12181 et seq. – Title III of the Americans with Disabilities Act
- Violation of New York State Human Rights Law, N.Y. Exec. Law Article 15 (Executive Law § 292 et seq.)
- Violation of New York State Civil Rights Law, NY CLS Civ R, Article 4 (CLS Civ R § 40 et seq.
- Violation of New York City Human Rights Law, N.Y.C. Administrative Code § 8-102, et seq.
- Declaratory Relief
Plaintiff seeks the following relief by way of its Complaint:
- A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., and N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York
- A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make its website, Birddogs.com, into full compliance with the requirements set forth in the ADA, and its implementing regulations, so that Birddogs.com is readily accessible to and usable by blind individuals
- A declaration that Defendant owns, maintains and/or operates its website, Birddogs.com, in a manner which discriminates against the blind and which fails to provide access for persons with disabilities as required by Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., and N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York
- An order certifying this case as a class action under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel
- An order directing Defendants to continually update and maintain its website to ensure that it remains fully accessible to and usable by the visually-impaired
- Compensatory damages in an amount to be determined by proof, including all applicable statutory damages and fines, to Plaintiff and the proposed class for violations of their civil rights under New York State Human Rights Law and City Law
- Plaintiff’s reasonable attorneys’ fees, expenses, and costs of suit as provided by state and federal law
- For pre- and post-judgment interest to the extent permitted by law; and i) For such other and further relief which this court deems just and proper.