MARY CONNER, represented by SHAKED LAW GROUP PC , filed suit in Federal of New York on January 3, 2019 alleging that PARKWOOD ENTERTAINMENT LLC, website www.Beyonce.com is not accessible using the following testing standard(s): WCAG 2.1, Section 508. PARKWOOD ENTERTAINMENT LLC, is in the Entertainment industry.
The plaintiff alleges the following issues:
Case arises out of Parkwood’s policy and practice of denying the blind access to the goods and services offered by Beyonce.com. Due to Parkwood’s failure and refusal to remove access barriers to Beyonce.com, blind individuals have been and are being denied equal access to Beyonce, as well as to the numerous goods, services and benefits offered to the public through Beyonce.com.
The specific laws that PARKWOOD ENTERTAINMENT LLC, allegedly violated include:
- Violation of 42 U.S.C. §§ 12181 et seq. – Title III of the Americans with Disabilities Act
- Violation of New York State Human Rights Law, N.Y. Exec. Law Article 15 (Executive Law § 292 et seq
- Violation of New York State Civil Rights Law, NY CLS Civ R, Article 4 (CLS Civ R § 40 et seq.)
- Violation of New York City Human Rights Law, N.Y.C. Administrative Code § 8-102, et seq
- Declaratory Relief
The plaintiff is seeking the following (Prayer for relief):
- A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., and N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York;
- A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make its website, Beyonce.com, into full compliance with therequirements set forth in the ADA, and its implementing regulations, so that Popsockets.com is readily accessible to and usable by blind individuals;
- A declaration that Defendant owns, maintains and/or operates its website, Beyonce.com, in a manner which discriminates against the blind and which fails to provide access for persons with disabilities as required by Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., and N.Y.C. Administrative Code § 8-107, et seq., and the laws of New York;
- An order certifying this case as a class action under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel;
- An order directing Defendants to continually update and maintain its website to ensure that it remains fully accessible to and usable by the visually-impaired;
- Compensatory damages in an amount to be determined by proof, including all applicable statutory damages and fines, to Plaintiff and the proposed class for violations of their civil rights under New York State Human Rights Law and City Law;
- Plaintiff’s reasonable attorneys’ fees, expenses, and costs of suit as provided by state and federal law;
- For pre- and post-judgment interest to the extent permitted by law; and
- For such other and further relief which this court deems just and proper.