HECHT v. PRECIOUS MOMENTS COMPANY INC.

Many features on the Website:

• fail to accurately describe the contents of graphical images,
• fail to properly label title
• fails to distinguish one page from another
• contain multiple broken links
• contain headings that do not describe the topic or purpose
• the keyboard user interfaces lack a mode of operation where the keyboard focus indicator is visible

• VIOLATIONS OF THE ADA, 42 U.S.C. § 12181 et seq
• VIOLATIONS OF THE NYCHRL
• DECLARATORY RELIEF

• A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York
• A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make its Website into full compliance with the requirements set forth in the ADA, and its implementing regulations, so that the Website is readily accessible to and usable by blind individuals
• A declaration that Defendant owns, maintains and/or operates its Website in a manner that discriminates against the blind and which fails to provide access for persons with disabilities as required by Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York
• An order certifying the Class and Sub-Classes under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and her attorneys as Class Counsel
• Compensatory damages in an amount to be determined by proof, including all applicable statutory and punitive damages and fines, to Plaintiff and the proposed class and subclasses for violations of their civil rights under New York City Human Rights Law and City Law
• Pre- and post-judgment interest
• An award of costs and expenses of this action together with reasonable attorneys’ and expert fees
• Such other and further relief as this Court deems just and proper.