- Name: Brittney Mejico
- Filing date: February 9, 2021
- State of filing: California
- Name: Surveymonkey, Inc.
- Website: www.surveymonkey.com
- Industry: Internet Software and Services
- Summary: Surveymonkey is an online survey tool allowing individual and business users to conduct surveys via email and a website interface.
On February 9, 2021, Brittney Mejico filed a Complaint in California State court against Surveymonkey, Inc.. Plaintiff Brittney Mejico alleges that www.surveymonkey.com is not accessible per the WCAG 2.0 accessibility standard(s).
Plaintiff alleges issues in its Complaint including the following:
- Missing alternative text which presents a problem because an image without alternative text results in an empty link.
- Spacer image missing alternative text which presents a problem because a layout spacer image does not have an alt attribute. Spacer images are used to maintain layout. They do not convey content and should be given null/empty alternative text (alt=””) so they are not presented to users and are ignored by screen readers;
- Empty or missing form labels which presents a problem because, if a form control does not have a properly associated text label, the function or purpose of that form control may not be presented to screen reader users. Empty or missing form labels provide visible descriptions and larger clickable targets for form controls;
- Empty buttons, which present a problem because a button is empty or has no value text.
- Empty headings, which present a problem because a heading contains no content.
- Redundant Links where adjacent links go to the same URL address which results in additional navigation and repetition for keyboard and screen reader users.
Plaintiff asserts the following cause(s) of action in its Complaint:
Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.
Plaintiff seeks the following relief by way of its Complaint:
- 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 Websites readily accessible to and usable by visually-impaired individuals, but Plaintiff hereby expressly limit the injunctive relief to require the Defendant expend no more than $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 limit 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 t 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.