LICEA v. NORTHERN SAFETY CO., INC.

• Linked image missing alternative text which presents a problem because an image without alternative text results in an empty link. Images that are the only thing within a link must have descriptive alternative text. If an image is within a link that contains no text and that image does not provide alternative text, a screen reader has no content to present to the user regarding the function of the 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. Form labels provide visible descriptions and larger clickable targets
  for form controls;
• Empty headings, which present a problem because a heading contains no content. Keyboard and screen reader users often navigate by heading elements. An empty heading will present no information and may introduce confusion;
• Empty links which present a problem because a link contains no text. If a link contains no text, the function or purpose of the link will not be presented to the user. This can introduce confusion for keyboard and screen reader users;
• Broken ARIA menu, which presents a problem because an ARIA menu does not contain required menu items. ARIA menus are application menus (like those used in software menu) with a specific keyboard interactions. They are NOT for navigation links on a web site and must contain at least one menuitem, menuitemcheckbox, or menuitemradio element; and
• Redundant Links where adjacent links go to the same URL address which results in additional navigation and repetition for keyboard and screen reader users.

Unruh Civil Rights Act, California Civil Code § 51 et seq

• 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, https://www.northernsafety.com/, readily accessible to and usable by visually-impaired 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 toexceed $74,999;
• For pre-judgment interest to the extent permitted by law;
• For costs of suit; and
• For such other and further relief as the Court deems just and proper.