- Name: Andres Gomez
- Filing date: March 29, 2021
- State of filing: California
- Name: Dream Hotel Group LLC
- Website: www.dreamhotels.com
- Industry: Hotel, Restaurant and Leisure
- Summary: Dream Hotel Group LLC owns and operates a chain of Dream luxury hotels across the globe.
On March 29, 2021, Andres Gomez filed a Complaint in California State court against Dream Hotel Group LLC. Plaintiff Andres Gomez alleges that www.dreamhotels.com is not accessible per the WCAG 2.0 accessibility standard(s).
Plaintiff alleges issues in its Complaint including the following:
- Images on the website lack a text equivalent readable by
- Navigation elements are not properly labeled as headings
to enable SRS to recognize them as navigation elements.
- The website contains script elements that are not identified with functional text readable by SRS.
- The website contains form elements that are not identified
with functional text readable by SRS.
- Where alternative text elements are found, they are similar
or identical to adjacent or nearby elements.
- Accessible elements are contained within “noscript”
- The website contains empty orredundant links resulting in
additional and inefficient navigation by SRS users.
- The visualization of the webpage contains impermissibly
low contrast enabling differentiation of background and
- Audio/Visual Content is provided without a text
Plaintiff asserts the following cause(s) of action in its Complaint:
- Title III of the ADA, 42 U.S.C. § 12181 et seq.
- Section 504 of the Rehabilitation Act
Plaintiff seeks the following relief by way of its Complaint:
- A Declaratory Judgment that at the commencement of this action Defendant was in violation of the specific requirements of Title III of the ADA described above, and the relevant implementing regulations of the ADA, in that Defendant took no action that was reasonably calculated to ensure that its app is fully accessible to, and independently usable by, blind individuals.
- A permanent injunction pursuant to 42 U.S.C. § 12188(a)(2) and 28 CFR § 36.504 (a) which directs Defendant to take all steps necessary to brings its app into full compliance with the requirements set forth in the ADA, and its implementing regulations, so that its app is fully accessible to, and independently usable by, blind individuals, and which further directs that the Court shall retain jurisdiction for a period to be determined to ensure that Defendant has adopted and is following an institutional policy that will in fact cause Defendant to remain fully in compliance with the law
- Payment of costs of suit
- Payment of reasonable attorneys’ fees, pursuant to 42 U.S.C. § 12205 and 28 CFR § 36.505
- The provision of whatever other relief the Court deems just, equitable and appropriate.