JOEL PRICE vs. ORANGE BUICK GMC, INC

• Defendant’s Website is not designed with consideration for Universal design. Universal design is necessary so that visually impaired individuals who use screen reader software can access the Website
• Furthermore, Defendant’s Website does not have the sign of website accessibility
• Defendant’s Website was inaccessible so Plaintiff could not purchase an automobile online. Neither could Plaintiff: a. learn about Orange Buick GMC’s inventory of new and used automobiles; b. apply for an automobile loan and become pre-approved for purchase or lease of an automobile prior to traveling to Orange Buick GMC; c. participate in an on-line chat regarding automobiles for sale; and/or d. utilize the online scheduling system for automobile service or repair as the non-disabled public.

VIOLATIONS OF THE AMERICANS WITH DISABILITIES ACT

• WHEREFORE, Plaintiff Joel Price hereby demands judgment against Defendant ORANGE BUICK GMC and requests the following injunctive and declaratory relief permanently enjoin Defendant from any practice, policy and/or procedure which will deny Plaintiff (and other individuals with visual impairments) equal access to, and benefit from Defendant’s services, programs, activities and facilities, as well as:
• The Court issue a declaratory judgment that Defendant has violated Plaintiff’s rights as guaranteed by the ADA;
• The Court enter an Order requiring Defendant to update its www.orangebuickgmc.com website to remove barriers in order that individuals with visual disabilities can access the Website and effectively communicate with the Website to the full extent required by Title III of the ADA;
• The Court enter an Order requiring Defendant to clearly display the universal disabled logo and sign of website accessibility within itsWebsite. Such a clear display is to ensure that individuals who are disabled are aware of the availability of the accessible features of the www.orangebuickgmc.com website;
• The Court enter an Order to compel Defendant to contract with an independent ADA expert/consultant for the purposes of that ADA expert/consultant review Defendant’s policies, practices and procedures for five years commencing from the date of the Court’s Order to insure that Defendant is in compliance with the ADA;
• The Court enter an order requiring Defendant to provide ongoing support for web accessibility by implementing a website accessibility coordinator, a website application accessibility policy, and providing for website accessibility feedback to insure compliance thereto;
• The Court enter an Order directing Defendant to evaluate its policies, practices and procedures toward persons with disabilities, for such reasonable time so as to allow Defendant to undertake and complete corrective procedures to the Website;
• The Court award damages in an amount to be determined at trial;
• The Court to award Plaintiff reasonable litigation expenses and attorneys’ fees; and
• That the Court award such other and further relief as it deems necessary, just and proper.