Sealed forensic record · Report #679

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

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

**ADA Title III Web Accessibility — Consumer-Facing Platform** This matter alleges violations of Title III of the Americans with Disabilities Act, the Unruh Civil Rights Act, and New York State Human Rights Law, following the framework established in *Robles v. Domino's Pizza, Inc.*, 9th Cir. An automated accessibility audit of a consumer-facing digital platform identified 5 accessibility violations across scanned pages. No third-party tracking activity was detected. The sealed PDF chain-of-custody includes 9 screenshots documenting the findings across approximately 15–25 pages.

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.