Carlton Knowles v. Carnivore Snax LLC

Case Summary

According to the complaint, Carlton Knowles, a visually-impaired individual, is suing Carnivore Snax LLC for failing to make its website, www.carnivoresnax.com, accessible to blind users. The plaintiff alleges that he encountered numerous barriers while trying to access information and purchase products, including missing alt-text for images and broken links. The complaint cites violations of the Americans with Disabilities Act (ADA) and seeks a permanent injunction to require the defendant to improve website accessibility, along with compensatory damages for the alleged discrimination.

Causes of Action

• Violations of the ADA
• Violations of the NYSHRL
• Violations of the NYCHRL
• Violation of GBL § 349

Key Allegations

• Defendant's website is not accessible to blind and visually-impaired individuals.
• Plaintiff encountered multiple access barriers while attempting to use the website.
• Defendant has failed to comply with the ADA and other relevant laws.

Requested Relief

• Permanent injunction requiring Defendant to make its website accessible to blind individuals.
• Compensatory damages for violations of civil rights under New York State Human Rights Law and GBL § 349.
• Reasonable attorneys’ fees and costs.

Proposed Class

All legally blind individuals in the United States who have attempted to access Defendant’s Website and as a result have been denied access to the equal enjoyment of goods and services offered by Defendant’s Website, during the relevant statutory period.

Jurisdiction & Venue

The Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12181, and supplemental jurisdiction under 28 U.S.C. § 1367.