Plaintiff
- Name: Luis Licea Dominick Martin
- Filing date: July 23, 2020
- State of filing: California
Defendant
- Name: Carwin Pharmaceuticals Associates LLC
- Website: www.carwinpharma.com
- Industry: Pharmaceuticals
- Summary: Carwin Pharmaceuticals is a privately-held specialty pharmaceutical company focused on Pediatrics and Women's Health.
Case Summary
On July 23, 2020, Luis Licea Dominick Martin filed a Complaint in California State court against Carwin Pharmaceuticals Associates LLC . Plaintiff Luis Licea Dominick Martin alleges that www.carwinpharma.com is not accessible per the WCAG 2.0 accessibility standard(s).
Case Details
Plaintiff alleges issues in its Complaint including the following:
- Linked image missing alternative text which presents a problem because an image without alternative text results in an empty link.
- Empty or missing form labels which presents a problem because, if a form control does not have a properly associated text label, the function or purpose of that form control may not be presented to screen reader users
- Empty buttons, which present a problem because a button is empty or has no value text
- Empty links that contain no text causing the function or purpose of the link to not be presented to the user
- Redundant Links where adjacent links go to the same URL address
Plaintiff asserts the following cause(s) of action in its Complaint:
- Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.
Plaintiff seeks the following relief by way of its Complaint:
- For a judgment that Defendant violated Plaintiffs’ rights under the Unruh Civil Rights Act, California Civil Code § 51 et seq.
- For a preliminary and permanent injunction requiring Defendant to take the steps necessary to make the Website, www.carwinpharma.com, readily accessible to and usable by visuallyimpaired individuals; but Plaintiffs hereby expressly limit the injunctive relief to require that Defendant expend no more $20,000 as the cost of injunctive relief
- An award of statutory minimum damages of $4,000 per violation pursuant to section 52(a) of the California Civil Code; however, Plaintiffs expressly limit the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
- For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, California Civil Code § 52(a); however, Plaintiffs expressly limit the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
- For pre-judgment interest to the extent permitted by law
- For costs of suit
- For such other and further relief as the Court deems just and proper.
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