Langer

I. BACKGROUND

22 The following facts are alleged in the complaint and taken from the evidence submitted in 23 support of this motion. Langer suffers substantial and permanent partial hearing loss. FAC ¶¶ 1, 10. 24 He uses a variety of assistive devices, including hearing aids and headphones, but he still does not 25 receive “complete aural communication.” Id. ¶ 1. Thus, he relies on subtitles and closed captioning 26 while watching videos. Id. ¶¶ 1, 11. 27 Pep Boys is an “automotive aftermarket retail and services chain.” [Docket No. 20-1, Declaration of Gregory J. Russ (“Russ Decl.”) ¶ 5.] It sells tires and auto parts, repairs vehicles, and provides expert advice. Id. Pep Boys own and operate the Pep Boys website, which is available at https://www.pepboys.com. FAC ¶ 4. It also operates physical locations in California. Id. ¶ 12. Pep Boys offers videos on its website for various purposes, such as providing information and inducing customers to purchase its products. FAC ¶ 13. Langer alleges that he was a prospective customer seeking to access Pep Boy’s goods and services. Id. ¶ 14. He visited Pep Boys’ website in August…