Plaintiff
- Name: Dominick Martin
- Filing date: May 5, 2020
- State of filing: California
Defendant
- Name: Kampgrounds of America Inc.
- Website: www.koa.com
- Industry: Hotel, Restaurant and Leisure
- Summary: Kampgrounds of America is the world's largest system of privately held campgrounds with almost 500 locations across US and Canada.
Case Summary
On May 5, 2020, Dominick Martin filed a Complaint in California State court against Kampgrounds of America Inc. . Plaintiff Dominick Martin alleges that www.koa.com is not accessible per the WCAG 2.0 accessibility standard(s).
Case Details
Plaintiff alleges issues in its Complaint including the following:
- Missing alternative text
- Empty headings
- Empty buttons
- Empty links that contain no text
- Broken ARIA references
Plaintiff asserts the following cause(s) of action in its Complaint:
- Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq
Plaintiff seeks the following relief by way of its Complaint:
- For a judgment that Defendant violated Plaintiff’s rights under the Unruh Civil Rights Act, California Civil Code § 51 et seq.
- For a preliminary and permanent injunction requiring Defendant to take the steps necessary to make the Website, https://koa.com/, readily accessible to and usable by visually-impaired individuals; but Plaintiff hereby expressly limits the injunctive relief to require that Defendant expend no more $20,000 as the cost of injunctive relief
- An award of statutory minimum damages of $4,000 per violation pursuant to section 52(a) of the California Civil Code; however, Plaintiff expressly limits the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
- For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, California Civil Code § 52(a); however, Plaintiff expressly limits the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
- For pre-judgment interest to the extent permitted by law
- For costs of suit
- For such other and further relief as the Court deems just and proper.
