Sealed forensic record · Report #689

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: Washington

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-facing e-commerce platform. Plaintiff theory: failure to provide equal access to website functionality in violation of ADA Title III, *Robles v. Domino's Pizza, Inc.*, 9th Cir. 2019, and state accessibility statutes (Unruh Civil Rights Act, NY Human Rights Law). Audit captured 20 accessibility violations across scanned pages. Third-party tracking infrastructure present: 326 tracker fires logged. Representations of pricing and promotional terms documented, including "25% OFF 3 OR MORE," "35% OFF 5 OR MORE," "Free shipping to Nederland on all orders above €120.00," and "Buy 3+ save 25%, 5+ save 35% - applied in cart." Sealed PDF chain-of-custody: 30 screenshots, ~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.