Sealed forensic record · Report #683

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: Florida

Nat'l classScope varies — ADA Title III

ArbitrationArb risk — mass-arbitration target (enforceable clickwrap, high consumer volume, ~$525M rev)

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

**ADA Title III / Web Accessibility** This consumer-facing platform defendant faces exposure under Title III of the Americans with Disabilities Act, the framework established in *Robles v. Domino's Pizza* (9th Cir.), the California Unruh Civil Rights Act, and New York State Human Rights Law. The audit identified 10 accessibility violations across the scanned pages, rendering core functionality inaccessible to users with disabilities. Additionally, the site deployed 298 third-party trackers, creating separate privacy and compliance concerns. The sealed PDF chain of custody covers approximately 15–25 pages and 52 screenshots documenting the findings. --- **Sealed PDF:** ~15–25 pages | 52 screenshots with chain-of-custody seals

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.