MAGENO v. KAI RAMEN, INC.

• The home page has graphics, links, and buttons that are not labeled or are incorrectly labeled, or lack alternative text (“Alt-text”). Alt-text is invisible code embedded beneath a graphical image on a website. Web accessibility requires that Alt-text be coded with each picture so that screen-reading software can speak the Alt-text where a sighted user sees pictures. Alt-text does not change the visual presentation, but instead a text box shows when the cursor moves over the picture. The lack of Alt-text on these graphics prevents screen-readers from accurately vocalizing a description of the graphics.
• Plaintiff encountered multiple unlabeled or mislabeled buttons and links. Without descriptive alternate text, Plaintiffs, and other screenreader users, have no clue about the purpose or function of the button or
  link;
• Plaintiff encountered multiple pages containing insufficient navigational headings requiring Plaintiff to expend substantial additional time to access information;
• Plaintiff was unable to browse catering menu because catering menu links and descriptions were inaccessible to screen reading technology;
• Plaintiff was unable to find a brick-and-mortar location because the locations link was inaccessible to screen reading technology; and,
• Plaintiff was unable to make a purchase because of an inaccessible checkout system.
• Due to the unlabeled buttons, lack of Alt-text, the structure of the headings and Website, cursor traps, and other barriers, Plaintiff was unable to fully and independently access
  the Website when visiting for the dual purpose of testing for compliance with the UCRA and ADA and to review the menu, place an order, and visit the nearest brick-and-mortar location

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

• A Declaratory Judgment that at the commencement of this action Defendant was in violation of the specific requirements of Title III of the ADA 42 U.S.C. § 12181 et seq., and the relevant implementing regulations of the ADA, for Defendant’s failure to take action that was reasonably calculated to ensure that its Website is fully accessible to, and independently usable by, blind and visually-impaired individuals;
• A preliminary and permanent injunction enjoining Defendant from violating the ADA, 42 U.S.C. § 12181 et seq., and/or the UCRA, Civil Code § 51 et seq. with respect to its website lakushep.com;
• A preliminary and permanent injunction requiring Defendant to take the steps necessary to make lakushep.com readily accessible to and usable by blind and visually-impaired individuals;
• An award of statutory minimum damages of $4,000 per violation pursuant to § 52(a) of the California Civil Code;
• For attorneys' fees and expenses pursuant to all applicable laws including, without limitation, pursuant to 42 U.S.C. § 12188(a)(1), and California Civil Code § 52(a);
• For pre-judgment interest to the extent permitted by law;
• For costs of suit; and
• For such other and further relief as this Court deems just and proper.