Geovanni Bahena Figueroa v. Luxury Watches USA Corp.

Case Summary

According to the complaint, Plaintiff GEOVANNI BAHENA FIGUEROA, a visually-impaired individual, alleges that LUXURY WATCHES USA CORP. has failed to make its website, www.luxurywatchesusa.com, accessible to blind users, violating the Americans with Disabilities Act (ADA). The complaint details multiple access barriers encountered by the Plaintiff, including missing alt-text and broken links, which hindered his ability to purchase a desired watch. Plaintiff seeks injunctive relief to compel the Defendant to comply with accessibility standards and to ensure equal access for visually-impaired consumers. The case is filed as a class action on behalf of all legally blind individuals who have faced similar barriers on the Defendant's website.

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 preventing full use of the website.
• Defendant failed to comply with WCAG 2.1 guidelines.

Requested Relief

• Preliminary and permanent injunction to prohibit violations of the ADA.
• Injunction requiring compliance with ADA standards.
• Declaration of discriminatory practices against blind individuals.
• Class certification and appointment of Plaintiff as Class Representative.
• Payment of nominal damages.
• Pre- and post-judgment interest.
• Award of costs and expenses, including attorney fees.

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).