SHAHBAZ v. BARNES & NOBLE, INC.

• A proper text equivalent for every non-text element is not provided;
• Alternatives that present information in a way that sight or hearing impaired visitors can use is not provided for audio-only or video-only prerecorded media presentations;
• Information about the meaning and structure of content is not conveyed by more than the visual presentation of content.
• On pages where a user can move to a part of a page via the keyboard, the user is unable to move away from that part of the page using only the keyboard;
• A mechanism is not always available to bypass blocks of content that are repeated on multiple web pages;
• Web pages lack titles that describe their topic or purpose;
• The purpose of each link cannot be determined from the link text alone or from the link text and its programmatically determined link context;
• The default human language of each Web page cannot be programmatically determined;
• Changing the setting of any user interface component may automatically cause a change of context unless the user has been informed before using the component;
• Labels or instructions are not always provided when content requires user input;
• In content implemented using markup languages, elements do not always have complete start and end tags, are nested according to their specifications, may contain duplicate attributes, and IDs are not always unique.

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

• A minimum of $4,000.00 in statutory damages;
• For treble damages;
• For permanent injunctive relief;
  For attorney’sfees and costs;
• For such other and further relief as to the Court seems just and proper.