Plaintiff
- Name: Constance Henry
- Filing Date: March 19, 2026
- Court: United States District Court Northern District of Illinois
- State: Illinois
- Attorney Firm: Equal Access Law Group, PLLC
Defendant
- Name: Prime Prometics, Inc.
- Website: www.primeprometics.com
- Industry: Beauty
- Standards Cited: WCAG 2.2
- Summary: Provides consumers access to an array of beauty and cosmetic products, including eyeshadow sticks, mascaras, eyeliners, CC creams, foundations, blushes, lip color sticks, brow gels, brow pencils, hairline powders, and other cosmetic products designed for mature skin.
Case Summary
According to the complaint, Constance Henry, a visually impaired individual, is suing Prime Prometics, Inc. for failing to make its website, primeprometics.com, accessible to blind users. Henry alleges that the website contains significant barriers that prevent her and others from independently navigating and completing transactions. The complaint cites violations of the Americans with Disabilities Act (ADA) and seeks both injunctive relief to make the website accessible and compensatory damages for the discrimination faced. Henry's attempts to purchase products were thwarted by the website's design, which does not accommodate screen-reading software, thus denying her equal access to the goods and services offered online.
Causes of Action
- Violation of the Americans with Disabilities Act (ADA)
- Declaratory Relief
Key Allegations
- Website is inaccessible to visually impaired individuals
- Access barriers prevent independent navigation and transactions
- Defendant failed to implement necessary accessibility features
Requested Relief
- Preliminary and permanent injunction to prohibit Defendant from violating the ADA
- Injunction requiring Defendant to make the Website compliant with the ADA
- Declaration that the Website discriminates against the visually impaired
- Order certifying this case as a class action
- Pre- and post-judgment interest
- Award of costs and expenses of this action together with reasonable attorneys’ and expert fees
Proposed Class
all legally blind individuals in the United States who have attempted to access the Website and as a result have been denied access to the enjoyment of goods and services offered by the Website, during the relevant statutory period.
Jurisdiction & Venue
This Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182; venue is proper under 28 U.S.C. §1391(b)(1) and (2).
