Licea v. Lavender Lingerie, LLC

Summary

On April 2, 2019, Luis Licea filed a Complaint in California State court against Lavendar Lingerie LLC. Plaintiff Luis Licea alleges that www.savagex.com is not accessible.

About the defendant

Lavendar Lingerie LLC manufactures and sells women's lingerie under the brand name, Savage Fenty.

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.
• Broken ARIA references.
• Redundant Links where adjacent links go to the same URL address which results in additional navigation and repetition for keyboard and screen reader users.

Legal claims

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

• 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, www.savagex.com/?ref=http%3A//www.rihannanow.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, withoutlimitation, 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; and
• For such other and further relief as the Court deems just and proper