LUCIUS v. BONPOINT USA INC.

• the Account icon image does not have a label. It is announced only as "clickable."
• Size options that are not in stock are displayed onscreen with a strikethrough, but this is not announced to screen reader users. Users hear each size as if it's available. They do not hear if a size is out of stock.
• The Account icon is required to be accessible by the Tab key, but it is not. There is no skip to content link.
• Keyboard focus order is not working sequentially. The focus order does not go to the sub links of the header link from the left navigation menu.
• The initial screen in the Size Guide pop-up is announced, however, focus does not move to the new section when it is displayed. For example, users accessed the Woman size guide and could see it displayed onscreen, however, focus remained on the first page and users were unable to hear any of the newly displayed size content for Women.

VIOLATION OF TITLE III OF THE AMERICANS WITH DISABILITIES ACT

• The Court issue a declaratory judgment that determines that 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.
• the court issue a declaratory judgment that determines that 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.