Plaintiff
- Name: Shael Cruz
- Filing date: November 25, 2020
- State of filing: New York
Defendant
- Name: Healthy Paws Pet Insurance LLC
- Website: www.healthypawspetinsurance.com
- Industry: Pet Products
- Summary: Healthy Paws Pet Insurance LLC offers a variety of pet health insurance plans.
Case Summary
On November 25, 2020, Shael Cruz filed a Complaint in New York Federal court against Healthy Paws Pet Insurance LLC . Plaintiff Shael Cruz alleges that www.healthypawspetinsurance.com is not accessible per the WCAG 2.1 accessibility standard(s).
Case Details
Plaintiff alleges issues in its Complaint including the following:
- Lack of Alternative Text (“alt-text”), or a text equivalent.
- Empty Links That Contain No Text
- Redundant Links where adjacent links go to the same URL address
- Linked Images Missing Alt-text
- Texts throughout the website providing information regarding the product offer were not labeled to integrate with the screen reader.
- Company logo link is not properly labeled
- Site information located at the footer of the website such as phone number, fax information, and address were not labeled to integrate with the screen reader.
Plaintiff asserts the following cause(s) of action in its Complaint:
- VIOLATIONS OF THE ADA, 42 U.S.C. § 12181 et seq.
- VIOLATIONS OF THE NYSHRL
- VIOLATION OF THE NEW YORK STATE CIVIL RIGHTS LAW
- VIOLATIONS OF THE NYCHRL
- DECLARATORY RELIEF
Plaintiff seeks the following relief by way of its Complaint:
- A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York
- A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make its Website into full compliance with the requirements set forth in the ADA, and its implementing regulations, so that the Website is readily accessible to and usable by blind individuals
- A declaration that Defendant owns, maintains and/or operates its Website in a manner that discriminates against the blind and which fails to provide access for persons with disabilities as required by Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York
- An order certifying the Class and Sub-Classes under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel
- Compensatory damages in an amount to be determined by proof, including all applicable statutory and punitive damages and fines, to Plaintiff and the proposed class and subclasses for violations of their civil rights under New York City Human Rights Law and City Law
- Pre- and post-judgment interest
- An award of costs and expenses of this action together with reasonable attorneys’ and expert fees
- Such other and further relief as this Court deems just and proper.
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