RENDON v. STUDY.COM, LLC

• 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. Form labels provide visible descriptions and larger clickable targets for form
  controls;
• Multiple form labels, which presents a problem because a form control has more than one label associated with it. A form control should have at most one associated label element. If more than one label element is associated to the control, assistive technology may not read the appropriate label ;
• 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.

Violations of the 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 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.