Mejico v. Knowbe4, Inc.

Summary

On March 24, 2021, Brittney Mejico filed a Complaint in California State court against KNOWBE4 INC.. Plaintiff Brittney Mejico alleges that www.knowbe4.com is not accessible per the WCAG 2.0 accessibility standard(s).

About the defendant

KnowBe4 is an internet security corporation providing software, services, and consultation in security and governnace.

What the complaint says

The problems the plaintiff describes with the website.

• Empty headings, which present a problem because a heading contains no content. Keyboard andscreen reader users often navigate by heading elements. An empty heading will present no informationand may introduce confusion;
• Empty links which present a problem because a link contains no text. If a link contains no text, the function or purpose of the link will not be presented to the user.This can introduce confusion for keyboard and screen reader users; and Redundant Links where adjacent links go to the same URL address which results in additionalnavigation and repetition for keyboard and screen reader users.
• Redundant Links whereadjacent links go to the same URL address which results in additional navigation and repetition forkeyboard and screen reader users

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 Plaintiff’s 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 readily accessible to and usable by visually-impaired individuals, but Plaintiff hereby expressly limit the injunctive relief to require the Defendant expend no more than $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, Plaintiff 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, Plaintiff expressly limits the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not t exceed $74,999;
• For pre-judgment interest to the extent permitted by law;
• For costs of suit; and
• For such other and further relief as the Court Deems just and proper.