ESPINOZA v. LOUIS VUITTON NORTH AMERICA, INC.

• Non-text content (CAPTCHA) that is presented to the user has a text alternative that serves the equivalent purpose. However, alternative form of CAPTCHA that uses output mode for different types of sensory perception doesn’t conform with WCAG guidelines.
  Standard 1.1.1 Non-text Content
• Labels or instructions are not provided when content requires user input. Standard 3.3.2 Labels or Instructions
• Some functionality of the content is not operable through a keyboard interface Standard 2.1.1 Keyboard

Americans with Disabilities Act, 42 U.S.C. § 12181 et seq. 

• A declaration that Defendant’s website is in violation of the ADA;
• An Order requiring Defendant, by a date certain, to update its website, and continue to monitor and update its website on an ongoing basis, to remove barriers in order that individuals with visual disabilities can access, and continue to access, the website and effectively communicate with the website to the full extent required by Title III of the ADA;
• An Order requiring Defendant, by a date certain, to clearly display the universal disabled logo within its website, wherein the logo [1] would lead to a page which would state Defendant’s accessibility information, facts, policies, and accommodations. Such a clear display of the disabled logo is to ensure that individuals who are disabled are aware of the availability of the accessible features of the website;
• An Order requiring Defendant, by a date certain, to provide ongoing support for web accessibility by implementing a website accessibility coordinator, a website application
  accessibility policy, and providing for website accessibility feedback to insure compliance thereto.
• An Order directing Defendant, by a date certain to evaluate its policies, practices and procedures toward persons with disabilities, for such reasonable time to allow Defendant to undertake and complete corrective procedures to its website;
• An Order directing Defendant, by a date certain, to establish a policy of web accessibility and accessibility features for its website to insure effective communication for individuals who are visually disabled;
• An Order requiring, by a date certain, that any third-party vendors who participate on Defendant’s website to be fully accessible to the visually disabled;
• An Order directing Defendant, by a date certain and at least once yearly thereafter, to provide mandatory web accessibility training to all employees who write or develop programs
  or code for, or who publish final content to, Defendant’s website on how to conform all web content and services with ADA accessibility requirements and applicable accessibility
  guidelines;
• An Order directing Defendant, by a date certain and at least once every three months thereafter, to conduct automated accessibility tests of its website to identify any instances
  where the website is no longer in conformance with the accessibility requirements of the ADA and any applicable accessibility guidelines, and further directing Defendant to send a copy of the twelve (12) quarterly reports to Plaintiff’s counsel for review.
• An Order directing Defendant, by a date certain, to make publicly available and directly link from its website homepage, a statement of Defendant’s Accessibility Policy to ensure the persons with disabilities have full and equal enjoyment of its website and shall accompany the public policy statement with an accessible means of submitting accessibility questions and problems.
• An award to Plaintiff of her reasonable attorney’s fees, costs and expenses; and
• Such other and further relief as the Court deems just and equitable.