LUCIUS v. KITON CORPORATION

• 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: the "Click to Order! Delivery, Carry Out, or Curbside" image is labeled as "Del Icon Dot PNG." This is the file name and not an informative description. It does not inform users that they can click this image to place an order.
• When a user presses the "Click to Order!" image then a new section of the website is revealed beneath the menu items. The new section is not announced, and focus does not move to it. Instead of hearing the online ordering section, focus moves to the next element at the top of the page, so it does not appear to users that pressing this button did anything.
• Users have to Tab through 17 other elements before they hear the newly displayed content.
• Skip content functionality is not available on this website.
• None of the buttons on the Booking Reservations page are in the Tab order, as required. If a screen reader user presses Tab then they hear one link at the very bottom of the page for Bookeo. All of the other content is skipped including the Enter Code button and the 4 Book buttons.
• Screen reader users cannot access the menus. For example, there are two menus on the Coral Gables page but they are both unlabeled images. The first menu is announced as "left parens eight right parens" and the second is announced as "left parens ten right parens."
• None of the text content in the menus are announced.

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.