LUCIUS v. NORTHFLEET CORPORATION

• Numerous portions of the website do not interface with and are not readable by SRS.
• There are three images located directly above the Footer section. Each image is different and has a different purpose but all three are announced the same "Our Client." Screen reader users do not hear the payment options, the SSL certificate or the Site Lock security logo. Users won't understand why they're hearing these elements or the purpose of these elements.
• An error message is displayed at the top of the cart page when an invalid coupon code has been entered but it is not announced. Screen reader users do hear "alert" but then the Remove button is announced followed by the other elements in the cart. The error message, at the top of the page is not announced which may prevent screen reader users from adding a coupon code.
• Skip functionality is not available. Screen reader users are not notified when a form error is present. User submitted a blank email field in the 15% off form. The email field vibrated and then turned red to indicate an error, but this was not announced. A promotional popup, announcing 15% off if a user provides an email address, is not announced to screen reader users. Error suggestions are not announced to screen reader users. Ex. the 15% off popup does turn the original hint text in the email field red but this is not accessible for screen reader users. A user who navigates up the form will hear the original hint text they hear when they first navigated the form. Instead of hearing an error suggestion, they hear the same hint text again. Users are not aware that an issue is present, and they don't hear a new error suggestion.

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.