WILLIAMS v. THE PAPER STORE LLC

    Plaintiff

    • Name: Pamela Williams
    • Filing date: March 15, 2020
    • State of filing: New York

    Defendant

    • Name: The Paper Store LLC
    • Website: www.thepaperstore.com
    • Industry: Consumer Goods
    • Summary: The Paper Store is the largest family-owned and operated specialty gift business in the Northeast.

    Case Summary

    On March 15, 2020, Pamela Williams filed a Complaint in New York Federal court against The Paper Store LLC. Plaintiff Pamela Williams alleges that www.thepaperstore.com is not accessible per the WCAG 2.1 accessibility standard(s).

    Case Details

    Plaintiff alleges issues in its Complaint including the following:

    • Many features on the Website lacks alt. text
    • Many features on the Website also fail to Add a label element or title attribute for each field
    • Many pages on the Website also contain the same title elements.
    • The Website also contained a host of broken links

    Plaintiff asserts the following cause(s) of action in its Complaint:

    • VIOLATIONS OF THE ADA, 42 U.S.C. § 12181 et seq.
    • VIOLATIONS OF THE NYCHRL
    • DECLARATORY RELIEF

    Plaintiff seeks the following relief by way of its Complaint:

    • A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., N.Y.C. Admin. Code § 8-107, et seq. and the laws of New York;
    • A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make its Website into full compliance with requirements set forth in the ADA and its implementing regulations, so that the Website is readily accessible to and usable by blind individuals;
    • A declaration that Defendant owns, maintains and/or operates its Website in a manner that discriminates against the blind and which fails to provide access for persons with disabilities as required by Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., N.Y.C. Admin. Code § 8-107, et seq. and the laws of New York;
    • An order certifying the Class and the State and City Sub-Classes under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel;
    • Compensatory and damages in an amount to be determined by proof, including all applicable statutory and punitive damages and fines, to Plaintiff and the proposed class for violations of their civil rights under the New York State Human Rights Law and New York City Law;
    • Pre- and post-judgment interest;
    • An award of costs and expenses of this action together with
      reasonable attorneys’ and expert fees; and
    • Such other and further relief as this Court deems just and proper.

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