Plaintiff
- Name: Luis Licea
- Filing date: July 15, 2020
- State of filing: California
Defendant
- Name: Zee.Dog LLC
- Website: www.zeedog.com
- Industry: Consumer Goods
- Summary: Zee Dog is a global online retailer of pet products.
Case Summary
On July 15, 2020, Luis Licea filed a Complaint in California State court against Zee.Dog LLC . Plaintiff Luis Licea alleges that www.zeedog.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 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 headings, which present a problem because a heading contains no content.
- 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 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.zeedog.com/, readily accessible to and usable by visuallyimpaired 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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