- Name: Andrew Baracco
- Filing date: December 14, 2020
- State of filing: California
- Name: L’Oreal USA S/D, Inc.
- Website: www.kiehls.com
- Industry: Beauty
- Summary: L’Oreal USA S/D, Inc. is a multinational beauty conglomerate that manufactures and sells a wide line of beauty products including Kiehl’s apothecary products.
On December 14, 2020, Andrew Baracco filed a Complaint in California State court against L’Oreal USA S/D, Inc.. Plaintiff Andrew Baracco alleges that www.kiehls.com is not accessible per the Section 508 accessibility standard(s).
Plaintiff alleges issues in its Complaint including the following:
- Lack of alt-text or text equivalent on graphics,
- Inaccessible forms,
- Lack of adequate prompting and labeling,
- Denial of keyboard access,
- Empty links and headings,
- Inability to complete important tasks using the keyboard and screen reader alone, and
- Content which is not fully readable or navigable using a screen reader.
Plaintiff asserts the following cause(s) of action in its Complaint:
Unruh Civil Rights Act, California Civil Code § 51 et seq.
Plaintiff seeks the following relief by way of its Complaint:
- A preliminary and permanent injunction enjoining Defendants from further violations of the UCRA, Civil Code §§ 51, et seq., with respect to their Website and all of the webpages and urls contained therein;
- A preliminary and permanent injunction requiring Defendants to take the steps necessary to make their Website readily and fully accessible to and usable by blind and visually impaired individuals. Plaintiff expressly limits the cost of injunctive relief sought in sections A and B to $15,000 or less;
- An award of statutory minimum damages of $4,000 per violation pursuant to § 52(a) of the California Civil Code;
- For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, pursuant to California Civil Code § 52(a);
- For pre-judgment interest to the extent permitted by law;
- For costs of suit; and
- For such other and further relief as this Court deems just and proper.