LUCIUS v. PANDORA JEWELRY LLC

•  the size options, shown in the “Select a Size” section do not announce the correct label or role. For example, when a user navigates to the 6.3 button, they do not hear the onscreen text label to let them know they are in the Select a Size
  section nor do they hear that a button is available. Instead, they only hear "6.3 link."
• Form errors are not announced to screen reader users when they are displayed onscreen.
• The close button in the after pay popup on the shopping bag page is not labeled. Screen reader users only hear "clickable." Users will become trapped in this window unless they know that the unlabeled button is actually the exit button. Users are presented with multiple financing offers on each product page such as Afterpay. The Afterpay link spawns a pop-up window, but the content in this pop-up is not
  accessible. Users only hear that an Afterpay graphic is present, but they do not hear any information for the content in the image.
• Error suggestions are shown onscreen but they are not
  announced when displayed.

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.