Sealed forensic record · Report #687

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: Arkansas

Nat'l classScope varies — ADA Title III

ArbitrationClass-viable — browsewrap, likely unenforceable

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

**ADA Title III Web Accessibility — Consumer Platform** A consumer-facing platform operates in violation of Title III of the Americans with Disabilities Act, as established in *Robles v. Domino's Pizza, Inc.* (9th Cir. 2021), and the Unruh Civil Rights Act and New York State Human Rights Law. The platform's website contains multiple barriers to access for users with disabilities. The audit identified 6 accessibility violations across the scanned pages. Third-party tracking infrastructure captured 293 tracker fires during the accessibility assessment. No verbatim representations of policy or intent were secured during this run. Sealed PDF chain-of-custody: 31 screenshots with forensic seals, ~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.