Sealed forensic record · Report #690

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-13k site)

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

**ADA Title III Web Accessibility — Consumer Photo Products Platform** This consumer-facing platform violates Title III of the Americans with Disabilities Act and the Unruh Civil Rights Act by failing to provide equal access to its web interface. The site contains 16 accessibility violations across scanned pages, preventing users with disabilities from independently navigating product offerings and promotional pricing. The platform displays prominent sale pricing throughout its catalog: "70% off," "65% off photo books," "Unlimited 4x6 prints for 1¢ ea.," "Matte photo tiles now $1.99," and "60% off ceramic mugs." Additional representations include "Folded greeting cards As low as $0.70 Sale Price $0.70 Regular Price $2.33," "Photo books From $5.60 Sale Price $5.60 Regular Price $15.99," and "Mugs From $6.40 Sale Price $6.40 Regular Price $15.99." These pricing representations are not equally accessible to screen-reader users or those navigating via keyboard. 26 verbatim representations captured. 14 screenshots with chain-of-custody seals. Sealed PDF (~15–25 pages) maintains forensic integrity.

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 2026-06-07).
No prior plaintiff-class filing found against this defendant in this lane.