Geovanni Bahena Figueroa v. Holistic Vet Blend, LLC

Case Summary

According to the complaint, Plaintiff GEOVANNI BAHENA FIGUEROA, a visually-impaired individual, is suing HOLISTIC VET BLEND, LLC for failing to make its website, www.holisticvetblend.com, accessible under the Americans with Disabilities Act (ADA). The plaintiff alleges that he encountered multiple barriers while attempting to access the website to purchase pet food, which denied him full and equal access to the goods and services offered. The complaint cites specific access issues such as missing alt-text and broken links that hinder the use of screen-reading software. The plaintiff seeks a permanent injunction to require the defendant to make the website accessible and to change corporate policies to ensure ongoing compliance with accessibility standards.

Causes of Action

• Violations of the ADA, 42 U.S.C. § 12182 et seq.
• Declaratory Relief

Key Allegations

• Defendant’s website is not accessible to blind and visually impaired individuals.
• Plaintiff encountered barriers that denied full access to the website.
• Defendant has failed to comply with the ADA requirements for website accessibility.

Requested Relief

• Permanent injunction requiring Defendant to make its website accessible to blind individuals.
• Certification of the Class under Fed. R. Civ. P. 23.
• Payment of nominal damages.

Proposed Class

All legally blind individuals in the United States who have attempted to access Defendant’s Website and as a result have been denied access to the equal enjoyment of goods and services, 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).