Sealed forensic record · Report #694

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

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 case invokes *Robles v. Domino's Pizza, Inc.* (9th Cir. 2019) and parallel statutes including the Unruh Civil Rights Act and New York State Human Rights Law. The defendant, a consumer-facing platform, maintained a public website with documented accessibility barriers preventing equal access to goods and services. The website contained 13 accessibility violations across scanned pages. Third-party tracking infrastructure fired 122 times during the audit. The defendant made representations including "USDA Certified Organic," "From happy hens free to roam on 50 acres," "21.8 Square Feet of Outdoor Space per Bird," "8+ Acres of Range per Farm," "130+ Small Family Farms," "824+ Total Acres of Happy Range," "we offer 21.8 square feet per bird," and "100% recyclable cartons." 33 verbatim representations were captured. 24 screenshots document the findings with chain-of-custody seals. The sealed PDF comprises approximately 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 2026-06-07).
No prior plaintiff-class filing found against this defendant in this lane.