Erika Randolph v. Calendars.com L.L.C.

Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Calendars.com L.L.C. for failing to make its website accessible under the Americans with Disabilities Act (ADA). Randolph alleges that the website contains significant barriers that prevent blind users from completing transactions, such as inadequate alt-text for images and reliance on mouse navigation. She seeks a permanent injunction to require the website to be accessible and compensatory damages for the discrimination faced. The complaint also seeks class action status for all legally blind individuals who have been denied access to the website.

About the defendant

Calendars.com provides a wide array of goods and services, including calendars and organizational products, allowing consumers to view and purchase items online.

What the complaint says

The problems the plaintiff describes with the website.

• Defendant's website is inaccessible to blind and visually-impaired persons.
• Plaintiff encountered multiple accessibility issues preventing her from completing a purchase.
• Defendant failed to implement necessary modifications to ensure website accessibility.

Legal claims

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

• Violation of 42 U.S.C. §§ 12181 et seq. - Title III of the Americans with Disabilities Act
• Declaratory Relief
• Negligent Infliction of Emotional Distress

What the plaintiff asks for

What the plaintiff wants the court to order.

• A preliminary and permanent injunction to prohibit Defendant from violating the ADA.
• An injunction requiring Defendant to make its website compliant with the ADA.
• A declaration that Defendant discriminates against the blind through its website.
• Class action certification and appointment of Plaintiff as Class Representative.
• Payment of nominal damages.
• Pre- and post-judgment interest.
• An award of costs and expenses of this action together with reasonable attorneys’ and expert fees.
• Punitive damages.
• Compensatory damages in an amount to be determined at trial.

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 Calendars.com and as a result have been denied access to the enjoyment of goods and services offered by Calendars.com, during the relevant statutory period.