Luis Licea v. Docusign, Inc.

Summary

On March 30, 2020, Luis Licea filed a Complaint in California State court against Docusign, Inc. . Plaintiff Luis Licea alleges that www.docusign.com is not accessible per the WCAG 2.0 accessibility standard(s).

About the defendant

DocuSign, Inc. provides cloud based software in the United States. The company offers e-signature solution that enables businesses to digitally prepare, execute, and act on agreements

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, https://www.docusign.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