Aaron See v. Volhard Dog Nutrition LLC

Summary

According to the complaint, Aaron See, a visually impaired individual, is suing Volhard Dog Nutrition LLC for failing to make its website accessible to blind and visually impaired users, violating the Americans with Disabilities Act (ADA). See alleges that the website contains significant barriers that prevent him and others from independently navigating and completing transactions. He seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the discrimination faced. The complaint highlights specific accessibility issues, including inadequate alt-text and reliance on visual interfaces, which hinder the ability of visually impaired individuals to access the website's offerings.

About the defendant

Provides consumers access to an array of goods and services, including the ability to purchase a wide selection of natural dog nutrition products, including dehydrated dog food diet mixes, holistic feeding foundations, dog treats, nutritional supplements, performance and recovery formulas, and wellness support products.

What the complaint says

The problems the plaintiff describes with the website.

• Website is inaccessible to blind and visually impaired individuals
• Significant access barriers prevent independent navigation and transactions
• Defendant's website design relies on an exclusively visual interface
• Failure to provide adequate alt-text and labeling for images and forms

Legal claims

The laws the plaintiff says the defendant broke, called causes of action.

• Violation of the Americans with Disabilities Act (ADA)

What the plaintiff asks for

What the plaintiff wants the court to order.

• Preliminary and permanent injunction to prohibit Defendant from violating the ADA
• Injunction requiring Defendant to make the Website compliant with the ADA
• Declaration that Defendant’s website discriminates against the visually impaired
• Class action certification
• Pre- and post-judgment interest
• Award of costs and expenses of this action together with reasonable attorneys’ and expert fees

Proposed class

The group of people the plaintiff asks to represent, so the case can cover them too.

all legally blind individuals in the United States who have attempted to access the Website and as a result have been denied access to the enjoyment of goods and services offered by the Website, during the relevant statutory period.