Sealed forensic record · Report #2248

**ADA Title III Web Accessibility** Consumer-facing platform defendant faces claims under 42 U.S.C. § 12181 (ADA Title III), *Robles v. Domino's Pizza, Inc.*, 9th Cir. 2019, California Unruh Civil Rights Act, and New York State Human Rights Law for barriers to digital access. Site audit captured 13 accessibility violations across scanned pages. Third-party tracking infrastructure fired 29 times during navigation. Four representations were documented verbatim: "[DEFENDANT] has just come out with a completely plastic-free water bottle — no plastic on the cap at all!"; "the reusable CO2 cartridges are returned to the manufacturer for refilling"; "all cardboard milk containers are coated inside and out with plastic, not wax"; and "Straus milk, which is available in natural grocery stores." Evidence sealed in 28 screenshots with chain-of-custody verification. Sealed PDF spans approximately 15–25 pages.