Abelardo Martinez v. QVC, Inc.

I. BACKGROUND

On May 13, 2020, Plaintiff commenced this action in the Los Angeles County Superior Court. (See Notice of Removal (“NoR”), Ex. A, Complaint (Docket No. 1- 1)). The Complaint alleges as follows: Plaintiff is a blind individual who requires screen reading software to read website content and access the internet. (Id. ¶ 4). Blind individuals may access websites by using keyboards in conjunction with screen reading software that vocalizes visual information on a computer screen. (Id. ¶ 13). Screen access software provides the only method by which a blind person may independently access the internet. (Id.). Unless websites are designed to be read by screen reading software, blind persons are unable to fully access websites and the information, products and services, privileges, advantages, and accommodations contained thereon. (Id.). The international website standards organization, W3C, has published version 2.0 of the Web Content Accessibility Guidelines (“WCAG 2.0”). (Id. ¶ 14). WCAG 2.0 are well-established, industry standard guidelines for ensuring websites are accessible to blind and visually-impaired people. (Id.). These guidelines are successfully…