Rosemarie Ramirez v. Episciences, Inc.

Case Summary

According to the complaint, plaintiff Rosemarie Ramirez, a visually-impaired individual, alleges that Defendant Episciences, Inc. has failed to make its website, www.epionce.com, accessible to blind users, violating the Americans with Disabilities Act (ADA). The plaintiff claims that due to various access barriers, including missing alt-text and broken links, she was unable to purchase a facial cream she desired. Ramirez seeks a permanent injunction requiring the defendant to comply with accessibility standards and to ensure that its website is usable by individuals with disabilities. The complaint also seeks class certification for all legally blind individuals who have faced similar issues accessing the website.

Causes of Action

• Violations of the ADA, 42 U.S.C. § 12182 et seq.
• Declaratory Relief

Key Allegations

• Defendant's website is not accessible to blind and visually-impaired individuals.
• Plaintiff was denied the ability to purchase products due to website inaccessibility.
• Defendant has failed to comply with WCAG 2.1 guidelines.

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the ADA.
• An order requiring Defendant to make its website fully compliant with the ADA.
• Payment of nominal damages.
• An 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 Defendant’s Website and as a result have been denied access to the equal enjoyment of goods and services, 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.