Sealed forensic record · Report #693

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: Illinois

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 involves alleged violations of the Americans with Disabilities Act Title III, as established in *Robles v. Domino's Pizza, Inc.* (9th Cir. 2019), the California Unruh Civil Rights Act, and New York State Human Rights Law. The defendant is a mid-market consumer-facing platform operating in the food/nutrition sector. Audit captured 13 accessibility violations across a consumer-facing digital property. The platform displays product marketing representations including: "Simple Mills is proud to be among the first brands to earn verification under the Non-UPF Verified Standard," "products composed primarily of minimally processed ingredients and free from hyper-engineered additives," "Nothing artificial, ever," "Made from a delicious and nutrient-dense seed flour blend, these organic crackers deliver antioxidants, fiber, and protein in each bite," "With 7g protein, 3g fiber (good source), and 92mg magnesium (excellent source)," "Certified Gluten Free and Non-GMO Project Verified," and "Grain free, corn free, gum free." No third-party tracking infrastructure was detected. Eight screenshots with forensic chain-of-custody seals document the violations across approximately 15–25 pages in the sealed PDF.

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.