- Name: Nutsuri Kidkul
- Filing date: February 18, 2020
- State of filing: California
- Name: American Rag CIE LLC
- Website: www.americanrag.com
- Industry: Apparel
- Summary: American Rag manufactures and sells designer casual wear for men and women.
On February 18, 2020, Nutsuri Kidkul filed a Complaint in California State court against American Rag CIE LLC. Plaintiff Nutsuri Kidkul alleges that www.americanrag.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,
- The lack of adequate prompting and labeling,
- The denial of keyboard access,
- Empty links and headings,
- Presence of pop ups which limit access to the content,
- PDF documents which are not fully readable using a screen reader and
- Inability to complete important tasks using the keyboard and screen reader alone.
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, https://americanrag.com/, 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.