LUCIUS v. DAVIDSTEA (USA) INC.

• Numerous portions of the website do not interface with and are not readable by SRS.
• More specifically, features of the website that are inaccessible to the visually impaired include, but
  are not limited to, the following: Defendant’s website contains graphics, links, headings, forms and text
  with information that is not fully readable and/or compatible with SRS.

Americans with Disabilities Act, 42 U.S.C. § 12181 et seq. 

• TheCourt issue a DeclaratoryJudgment that determinesthat theDefendant'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 DeclaratoryJudgment 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; and,
• Such other relief as the Court deems just and proper, and/or is allowable under Title III of the Americans with Disabilities Act.