LUCIUS v. RITA’S FRANCHISE COMPANY, LLC

• screen reader users cannot sign up for the Rita's Birthday eClub which provides specials, discounts, and other offers.
• The input fields do not have accessible labels, so each field is announced as "blank" when a screen reader Tabs to these fields.
• The visible labels are not programmatically associated with the input fields so blind users won't know what to enter. Form errors are not announced to screen reader users.
• Users attempting to submit an eClub form with errors, encounter a dialog box which is displayed but screen reader users do not hear the content or any error notification.
• They instead hear "assets.fbmta.com says ok button one of one."
• Screen reader users are not aware that an error is present and that the form was not submitted.
• The disclaimer directly beneath the eClub signup form is incorrectly announced as a list. Users hear "list with 9 items" when they arrive on the disclaimer.
• There are multiple images on the homepage slider. These images include text content, but the text is not announced nor navigable.
• Form error suggestions are displayed in a pop-up, but they are not announced when displayed and users are also unable to navigate in the dialog in order to trigger the error suggestion to be read.

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.