RENDON v. AMERIPRISE FINANCIAL, INC

• Missing alternative text which presents a problem because an image
  without alternative text results in an empty link. Alternative Text is invisible code embedded beneath
  a graphical image on a website. Web accessibility requires that Alternative Text be coded with each
  picture so that a screen reader can speak the Alternative Text where a sighted user sees pictures.
  Alternative Text does not change the visual presentation, but instead generates a text box that will popup when the mouse moves over the picture. The lack of Alternative Text on these graphics prevents
  screen readers from accurately vocalizing a description of the graphics;
• Linked image missing
  alternative text which presents a problem because an image without alternative text results in an empty
  link. Images that are the only thing within a link must have descriptive alternative text. If an image is
  within a link that contains no text and that image does not provide alternative text, a screen reader has
  no content to present to the user regarding the function of the link;
• Empty headings, which present
  a problem because a heading contains no content. Keyboard and screen reader users often navigate by
  heading elements. An empty heading will present no information and may introduce confusion;
• Empty buttons, which present a problem because a button is empty or has no value text. When
  navigating to a button, descriptive text must be presented to screen reader users to indicate the function
  of the button;
• Empty links that contain no text causing the function or purpose of the link to not be
  presented to the user. This can introduce confusion for keyboard and screen reader users;
• Broken ARIA menu, which presents a problem because an ARIA menu does not contain required menu items.
  ARIA menus are application menus (like those used in software menu) with a specific keyboard interactions. They are NOT for navigation links on a web site and must contain at least one menuitem, menuitemcheckbox, or menuitemradio element; and
• Redundant Links where adjacent links go to
  the same URL address which results in additional navigation and repetition for keyboard and screen
  reader users.

Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.

• 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 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.