ANNA MARIE DEFEO, represented by Alberto R. Leal Florida Bar No.: 1002345 The Leal Law Firm, P.A. 9314 Forest Hill Boulevard #62 Wellington, FL 33411 Phone: 561-237-2740 Facsimile: 561-237-2741 E-Mail: Attorney for Anna Marie DeFeo , filed suit in Federal of Florida on January 29, 2019 alleging that THEORY FLORIDA LLC website is not accessible using the following testing standard(s): WCAG 2.0. THEORY FLORIDA LLC is in the Apparel industry.

The plaintiff alleges the following issues:

The access barriers at the Website that Plaintiff has encountered include but are not limited to, the following: a) Text equivalent for every non-text element is not provided; b) Information about the meaning and structure of the Website’s content is not conveyed by more than the visual presentation of content; c) When the sequence in which content is presented affects its meaning, a correct reading sequence cannot be programmatically determined; d) Web pages do not have titles that describe topic or purpose; e) Images on the website are not explained to the user with use of a screen reader program;

The specific laws that THEORY FLORIDA LLC allegedly violated include:

Title III of the ADA, 42 U.S.C. § 12181 et seq


The plaintiff is seeking the following (Prayer for relief):

  • A Declaratory Judgment that at the commencement of this action Defendant was in violation of the specific requirements of Title III of the ADA described above, and the relevant implementing regulations of the ADA, in that Defendant took no action that was reasonably calculated to ensure that its Websites are fully accessible to, and independently usable by, blind individuals;
  • A permanent injunction pursuant to 42 U.S.C. § 12188(a)(2) and 28 CFR § 36.504 (a) which directs Defendant to take all steps necessary to bring the Website into full compliance with the requirements set forth in the ADA, and implementing regulations, so that the Website is fully accessible to, and independently usable by, blind individuals, and which further directs that the Court shall retain jurisdiction for a period to be determined to ensure that Defendant has adopted and is following an institutional policy that will in fact cause Defendant to remain fully in compliance with the law—the specific injunctive relief requested by Plaintiff is described more fully in Paragraph 6 above;
  • Pa yme n t of costs of suit;
  • Payment of reasonable attorneys’ fees, pursuant to 42 U.S.C. § 12205 and 28 CFR § 36.505; and,
  • The provision of whatever other relief the Court deems just, equitable and appropriate.