PHILLIP SULLIVAN, Jr., vs. GOLDMAN SACHS & CO. LLC,

This case arises out of Defendant’s policy and practice of denying the deaf and hard of hearing access to the Website, including the goods and services offered by Defendant through the Website. Due to Defendant’s failure and refusal to remove access barriers to the Website, deaf and hard-of-hearing individuals have been and are being denied equal access to the Website, as well as to the numerous goods, services and benefits offered to the public through the Website.

• Violation of New York State Human Rights Law, N.Y. Exec. Law, Article 15 (Executive Law § 292 et seq.)
• Violation of New York State Civil Rights Law, NY CLS Civ R, Article 4 (CLS Civ R § 40 et seq.)
• Violation of New York City Human Rights Law, N.Y.C. Administrative Code § 8-102, et seq.)
• Declaratory Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the N.Y. Exec. Law §296, et seq.,
• N.Y.C. Administrative Code § 8107 et seq.
• A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make the Website fully functional and compliant with WCAG 2.1 A and AA Standards so that the Website is readily accessible to and usable by deaf and hard of hearing individuals and other individuals with impairments, such as those who are visually impaired.
• A declaration that Defendant owns, maintains, and/or operates the Website in a manner which discriminates against the deaf and hard of hearing, and which fails to provide access for persons with disabilities as required by N.Y. Exec. Law § 296, et seq., N.Y.C. Administrative Code § 807 et seq. , and the laws of New York;
• Compensatory damages in an amount to be determined by proof, including all applicable statutory damages and fines, to Plaintiff for violations of their civil rights under New York State H uman Rights Law and City Law;