Plaintiff
- Name: Luis Licea
- Filing date: November 5, 2020
- State of filing: California
Defendant
- Name: Halo Innovations Inc
- Website: www.halosleep.com
- Industry: Consumer Goods
- Summary: Halo manufactures and sells baby sleep products including swaddles and sleepsacks.
Case Summary
On November 5, 2020, Luis Licea filed a Complaint in California State court against Halo Innovations Inc. Plaintiff Luis Licea alleges that www.halosleep.com is not accessible per the WCAG 2.0 accessibility standard(s).
Case Details
Plaintiff alleges issues in its Complaint including the following:
- Missing alternative text
- Linked image missing alternative text
- Empty or missing form labels
- Document language missing
- Empty headings
- Empty buttons
- Empty links that contain no text
- Redundant Links
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 Plaintiff’s 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, https://www.easybib.com/, readily accessible to and usable by visually-impaired individuals; but Plaintiff hereby expressly limits 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, Plaintiff expressly limits 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, Plaintiff expressly limits 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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