![]() ![]() ![]() Although styled as an individual action, the injunctive relief that Douglass seeks will inure to the benefit of an estimated 2.3 percent of the United States population who report having a visual disability,4 and to Defendant, who will extend its market reach to this population.5ģ. ![]() This includes individuals who have no vision at all as well as people who have low vision.Ģ. These provisions were enacted “to provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities” 2 by “assur equality of opportunity, full participation, independent living, and economic self-sufficiency.” 3ġ Douglass uses the word “blind” to describe individuals who, as a result of a visual impairment, have substantially limited eyesight. ![]() This action arises from Defendant’s failure to make its digital properties accessible to blind individuals, 1 which violates the effective communication and equal access requirements of Title III of the Americans with Disabilities Act (“ADA”), 42 U.S.C. Plaintiff Blair Douglass (“Douglass” or “Plaintiff”), for his Complaint against XXXXXXX (“XXXXXX” or “Defendant”), by and through his counsel, alleges upon personal knowledge as to himself and upon information and belief as to all other matters, based upon the investigation conducted by and through his counsel, which includes, among other things, an investigation of Defendant’s digital properties, as follows:ġ. Abramowicz, Chadler Steiger and Stephanie Moore, all throughout the Western District of Pennsylvania.ĬOMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF The following is an example lawsuit filed by Blair Douglass using attorney’s Kevin Tucker, Kevin J. East End Trial Group LLC – Kevin Tucker – Blair Douglass – Example Lawsuit ![]()
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