RIOS v. GROUPON, INC.

• Missing alternative text which presents a problem because an image without alternative text results in an empty link. Alternative Text is invisible code embedded beneath a graphical image on a website. Web accessibility requires that Alternative Text be coded with each picture so that a screen reader can speak the Alternative Text where a sighted user sees pictures. Alternative Text does not change the visual presentation, but instead generates a text box that will popup when the mouse moves over the picture. The lack of Alternative Text on these graphics prevents screen readers from accurately vocalizing a description of the graphics;
• Empty links that contain no text causing the function or purpose of the link to not be presented to the user. This can introduce confusion for keyboard and screen reader users;
• Empty headings, which present a problem because a heading contains no content. Keyboard and screen reader users often navigate by heading elements.
  An empty heading will present no information and may introduce confusion;
• Empty buttons, which present a problem because a button is empty or has no value text. When navigating to a button, descriptive text must be presented to screen reader users to indicate the function of the button; and
• Redundant Links where adjacent links go to the same URL address which results in additional navigation and repetition for keyboard and screen reader users.

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

• For a judgment that Defendant violated Plaintiff’s rights under the Unruh Civil Rights Act, California Civil Code § 51 et seq.;
• For a preliminary and permanent injunction requiring Defendant to take the steps necessary to make the Website, https://www.groupon.com/, readily accessible to and usable by visually-impaired individuals; but Plaintiff hereby expressly limits the injunctive relief to require that
  Defendant expend no more $20,000 as the cost of injunctive relief;
• An award of statutory minimum damages of $4,000 per violation pursuant to section 52(a) of the California Civil Code; however, Plaintiff expressly limits the total amount of recovery,
  including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999;
• For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, California Civil Code § 52(a); however, Plaintiff expressly limits the total amount of
  recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999;
• For pre-judgment interest to the extent permitted by law;
• For costs of suit; and
• For such other and further relief as the Court deems just and proper.