Erika Randolph v. Live Kaizen LLC

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Live Kaizen LLC for failing to make their website, Kaizenfoodcompany.com, accessible to blind users. The complaint alleges that the website contains significant barriers that prevent blind individuals from independently navigating and completing purchases. Randolph claims that these barriers violate the Americans with Disabilities Act (ADA). She seeks a permanent injunction to require Live Kaizen to make their website accessible and compensatory damages for the discrimination faced. The complaint also seeks class action status for all legally blind individuals who have faced similar issues with the website.

Causes of Action

• Violation of 42 U.S.C. §§ 12181 et seq. - Title III of the Americans with Disabilities Act
• Declaratory Relief
• Negligent Infliction of Emotional Distress

Key Allegations

• Defendant's website is not accessible to blind and visually-impaired persons
• Plaintiff encountered multiple access barriers preventing independent navigation and purchase
• Defendant failed to implement necessary modifications for accessibility

Requested Relief

• Preliminary and permanent injunction to prohibit violations of the ADA
• Injunction requiring compliance with ADA accessibility standards
• Declaration of discriminatory practices
• Class action certification
• Payment of nominal damages
• Pre- and post-judgment interest
• Award of costs and expenses
• Punitive damages
• Compensatory damages

Proposed Class

all legally blind individuals in the United States who have attempted to access Kaizenfoodcompany.com and as a result have been denied access to the enjoyment of goods and services offered by Kaizenfoodcompany.com, 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)