Luis Licea v. Abg-tretorn, LLC

Summary

On March 30, 2020, Luis Licea filed a Complaint in California State court against ABG-Tretorn, LLC. Plaintiff Luis Licea alleges that www.us.tretorn.com is not accessible per the WCAG 2.0 accessibility standard(s).

About the defendant

Authentic Brands Group LLC (ABG) is a New York City-based brand management company.

What the complaint says

The problems the plaintiff describes with the website.

• Missing alternative text which presents a problem because an image without alternative text results in an empty link
• Linked image missing alternative text which presents a problem because an image without alternative text results in an empty link.
• Empty or missing form labels which presents a problem because, if a form control does not have a properly associated text label, the function or purpose of that form control may not be presented to screen reader users.
• Empty headings, which present a problem because a heading contains no content.

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 Website, us.tretorn.com, readily accessible to and usable by visually-impaired individuals; but Plaintiff hereby expressly limits 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, Plaintiff expressly limits 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 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.