Sanchez

I. BACKGROUND1

Plaintiffs Jorge Sanchez and Matt Scott were teammates on the gold-medal-winning U.S. wheelchair basketball team at the 2020 Tokyo Paralympic Games. In 2023, they cele- brated a friend’s birthday at Barbarossa Lounge in San Francisco. Wheelchair accessibility

1 On a motion for default judgment, the moving party’s factual allegations are taken as true. See Cripps v. Life Ins. Co. of N. Am., 980 F.2d 1261, 1267 (9th Cir. 1992). barriers at the lounge unfortunately soured the evening. See Compl. ¶¶ 1–4, 12–13. To begin with, plaintiffs had trouble getting to their table: the lounge was crowded and there wasn’t a designated accessible path of travel. Once at their table, plaintiffs couldn’t fit the arms of their wheelchairs underneath the table because the table was too low. See id. ¶ 15. Then the biggest frustration came when plaintiffs needed to use the restroom. The only

restroom was downstairs, and there was no elevator or lift with access. See id. ¶ 16. The lounge had been renovated in 1997–1998 and 2015, for $250,000 and $425,000 respectively. See id. ¶ 2; Dkt. 14-3, Luciani Decl. ¶¶ 3, 6 & Ex. A.2 The 2015 renovation updated the “bar area, ground floor,…