Michael Wood v. Rug Pad USA LLC

Case Summary

According to the complaint, Michael Wood, a visually impaired individual, is suing Rug Pad USA LLC for failing to make its website accessible to blind users, violating the Americans with Disabilities Act (ADA). Wood alleges that the website contains significant barriers that prevent him and others from independently navigating and completing purchases. He seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the discrimination faced. The complaint highlights specific accessibility issues, including lack of alternative text for images and reliance on mouse navigation, which hinder visually impaired users from accessing the website's services.

Causes of Action

• Violation of the Americans with Disabilities Act (ADA)
• Declaratory Relief

Key Allegations

• Website is inaccessible to visually impaired individuals
• Denial of full and equal access to goods and services offered through the Website
• Failure to provide necessary accommodations for screen-reader users

Requested Relief

• Preliminary and permanent injunction to prohibit Defendant from violating the ADA
• Injunction requiring Defendant to make the Website compliant with the ADA
• Declaration that the Website discriminates against visually impaired individuals
• Order certifying this case as a class action
• Pre- and post-judgment interest
• Award of costs and expenses of this action together with reasonable attorneys’ and expert fees

Proposed Class

all legally blind individuals in the United States who have attempted to access the Website and as a result have been denied access to the enjoyment of goods and services offered by the Website, during the relevant statutory period.

Jurisdiction & Venue

This Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182; venue is proper under 28 U.S.C. §1391(b)(1) and (2).