LUCIUS v. ANN-FRANCES, INC.

• Numerous portions of the website do not interface with and are not readable by SRS.
• Size Charts are setup as unlabeled images.
• Screen reader users only hear "clickable."
• An accessible descriptive label is not present nor can users access any of the embedded text in the charts.
• The Quantity field has a text label, but it is not associated to the field. Users only hear "edit selected one" when they arrive on this field. They do not hear the name of the field they're on. The Size selector is an actionable element that is required to be in the Tab order, but it is not. Screen reader users who press Tab will jump directly to the Quantity field; they will not hear the Size selector. Skip functionality is not announced. Keyboard focus does not extend into the submenu items which prevents screen reader users from hearing and accessing these links.
• There are multiple accessibility issues with the Return form PDF. For example, the first error noted by Adobe's accessibility checker shows that the PDF is not tagged. If a user presses the Tab key while navigating the PDF then it does not take the user to the next element in the form, instead, users exit the PDF altogether.

Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.

• The Court issue a Declaratory Judgment that determinesthat the Defendant's website at the commencement of the subject lawsuit is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• TheCourt issue a Declaratory Judgment that determinesthat the Defendant's website is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• The Court issue a Declaratory Judgment that Defendant has violated the ADA by failing to monitor and maintain its website to ensure that it is readily accessible to and usable by persons with vision impairment
• That this Court issue an Order directing Defendant to alter its website to make it accessible to, and useable by, individuals with disabilities to the full extent required by Title III of the ADA
• That this Court enter an Order directing Defendant to evaluate and neutralize its policies and procedures towards persons with disabilities for such reasonable time so as to allow Defendant to undertake and complete corrective procedures
• That this Court enter an Order directing Defendant to continually update and maintain its website to ensure that it remains fully accessible to and usable by visually impaired individuals
• An award of attorney’s fees, costs and litigation expenses pursuant to 42 U.S.C. § 12205
• Such other relief as the Court deems just and proper, and/or is allowable under Title III of the Americans with Disabilities Act.