Sealed forensic record · Report #676

What's for sale here is a dated, hashed snapshot of a defendant's live tracking behavior, marketing representations, and consent UX, sealed under FRE 901 chain of custody on the day we captured it. Defendants rewrite their policies and pull their pixels the moment a complaint lands — this record is the only proof of what the site was doing before.

Case at a glance

LocationHQ: California

Nat'l classScope varies — ADA Title III

ArbitrationArb risk — mass-arbitration target (sign-in-wrap, high consumer volume, top-39k site)

ClaimsADA Title III / Robles v. Domino's (9th Cir.) / Unruh Civil Rights Act / NY State Human Rights Law

**ADA Title III Web Accessibility — Apparel Brand** Plaintiff theory: ADA Title III barrier to full and equal enjoyment of goods and services; Robles v. Domino's Pizza, Inc. (9th Cir. 2019); Unruh Civil Rights Act (Cal. Civ. Code § 51); NY Human Rights Law (NYHRL § 296). Mid-market apparel retailer's website contains 5 accessibility violations across scanned pages. Automated crawl detected 173 third-party tracker fires during site navigation. 28 screenshots with forensic chain-of-custody seals document the run. No wrap evidence or scope limitations encountered. Sealed PDF: ~15–25 pages, chain-of-custody maintained.

Case theory: ADA Title III / Robles

What you receive

Sealed PDF report (typical 15–28 pp) with full chain of custody — SHA-256 + RFC 3161 timestamps on every artifact
Verbatim binding representations with Wayback-anchored class-period bounds
Full network capture: every tracker fire, sensitive transmission, identity-sync event
Wrap classification: BROWSEWRAP / CLICKWRAP / SIGN-IN-WRAP verdict + Specht-line alignment
Per-circuit case-law alignment (LIKELY_UNENFORCEABLE / LIKELY_ENFORCEABLE / JURISDICTIONALLY_DEPENDENT)
Defendant name + domain — revealed at purchase

✓ Prior-litigation check: clear. No prior plaintiff-class filing found against this defendant on this theory (CourtListener federal + web search of state courts, checked 2026-06-08).
No prior plaintiff-class filing found against this defendant in this lane.