Plaintiff
- Name: Rusty Rendon
- Filing date: September 8, 2020
- State of filing: California
Defendant
- Name: H2O Plus LLC
- Website: www.h2oplus.com
- Industry: Beauty
- Summary: H2O Plus, LLC develops, manufactures, and distributes personal care products.
Case Summary
On September 8, 2020, Rusty Rendon filed a Complaint in California State court against H2O Plus LLC . Plaintiff Rusty Rendon alleges that www.h2oplus.com is not accessible per the WCAG 2.0 accessibility standard(s).
Case Details
Plaintiff alleges issues in its Complaint including the following:
- Missing alternative text which presents a problem because an image without alternative text results in an empty link.
- Linked image missing alternative text which presents a problem because an image without alternative text results in an empty link.
- Document language missing, which presents a problem because the language of the document is not identified.
- Empty or missing form labels which presents a problem because, if a form control does not have a properly associated text label, the function or purpose of that form control may not be presented to screen reader users
- Empty buttons, which present a problem because a button is empty or has no value text.
- Empty links which present a problem because a link contains no text.
- Redundant Links where adjacent links go to the same URL address which results in additional navigation and repetition for keyboard and screen reader users
Plaintiff asserts the following cause(s) of action in its Complaint:
- Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.
Plaintiff seeks the following relief by way of its Complaint:
- 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.h2oplus.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
- For such other and further relief as the Court deems just and proper.
