LUCIUS v. EL PALACIO DE LOS JUGOS, INC.

• the "Especiales por $5.99" video contains text about a promotional offer, but this video does not have an accessible alternative such as a full- text description. Activating the accessibility widget did not help with this issue. Screen reader users cannot hear the text under the promotional offer nor the information in this video.
• The menu page has four tabs; Comida, Jugos, Postres, Cafeteria. Users cannot navigate to hear the items displayed under each tab. For example, upon navigating to the Jugos tab users could see the results displayed, but screen reader users cannot scroll to hear the results. If a user presses the Tab key after navigating to the Jugos menu, the focus jumps to the banner at the top of the page and does not announce the menu items. If a user presses the arrow key, the next Tab is announced "Postres." Focus does not extend down to the menu results even with the accessibility widget activated. The "Search" and the "Current Location" icons, displayed on the Locations page, are not labeled. Both buttons are announced only as "clickable."
• Screen reader users are not notified when results are not returned on the Search form. If a user enters a misspelled location no results are returned, but screen reader users do not hear any information about the search, if they press the arrow key then they just hear "blank" or "clickable" if they navigate away from Search using the Tab key. The "Especiales por $5.99" video contains text about a promotional offer, but an audio description is not present, even with the accessibility widget activated.

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.