Abelardo Martinez, Jr. v. Bulletproof 360, Inc.

Summary

On July 17, 2020, Abelardo Martinez filed a Complaint in California State court against Bulletproof 360 Inc. . Plaintiff Abelardo Martinez alleges that www.bulletproof.com is not accessible.

About the defendant

Bulletproof 360, Inc. manufactures coffee and tea products.

What the complaint says

The problems the plaintiff describes with the website.

• Linked image missing alternative text
• Empty or missing form labels
• Empty links
• Empty headings
• Redundant Links where adjacent links go to the same URL address

Legal claims

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

• Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.

What the plaintiff asks for

What the plaintiff wants the court to order.

• For a judgment that Defendant violated Plaintiffs’ rights under the Unruh Civil Rights Act, California Civil Code § 51 et seq.
• For a preliminary and permanent injunction requiring Defendant to take the steps necessary to make the Websites, www.bulletproof.com readily accessible to and usable by visually-impaired individuals; but Plaintiffs hereby expressly limit the injunctive relief to require that Defendant expend no more $20,000 as the cost of injunctive relief
• An award of statutory minimum damages of $4,000 per violation pursuant to section 52(a) of the California Civil Code; however, Plaintiffs expressly limit the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
• For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, California Civil Code § 52(a); however, Plaintiffs expressly limit the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999
• For pre-judgment interest to the extent permitted by law
• For costs of suit
• For such other and further relief as the Court deems just and proper