Erika Randolph v. Z.One Concept USA, Inc.

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Z.One Concept USA, Inc. for failing to make their website, Us.milkshakehair.com, accessible to blind users. Randolph alleges that the website contains numerous barriers that prevent her and others with visual impairments from independently navigating and completing purchases. The complaint cites violations of the Americans with Disabilities Act (ADA) and seeks injunctive relief to require the defendant to make necessary changes to the website, as well as compensatory damages for the discrimination faced by Randolph and the class of similarly situated individuals.

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 inaccessible to blind and visually-impaired persons.
• Plaintiff encountered significant access barriers preventing her from completing a purchase.
• Defendant failed to implement necessary modifications to make the website accessible.

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act.
• A declaration that Defendant's website discriminates against the blind.
• Payment of nominal damages.
• Compensatory damages in an amount to be determined at trial.
• Punitive damages.

Proposed Class

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