Sealed forensic record · Report #695

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

LocationU.S. · operates nationally

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** This consumer-facing platform defendant faces exposure under Title III of the Americans with Disabilities Act, the Unruh Civil Rights Act, and New York State Human Rights Law, following the precedent established in *Robles v. Domino's Pizza* (9th Cir.). The site contains 12 accessibility violations across scanned pages, preventing users with disabilities from full and equal access to goods and services. Third-party tracking infrastructure—79 tracker fires detected—raises additional questions about data collection practices and user consent. Ten screenshots with chain-of-custody seals document the violations. The sealed PDF contains approximately 15–25 pages of evidence. --- **Sealed PDF: 10 screenshots with chain-of-custody 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 2026-06-07).
No prior plaintiff-class filing found against this defendant in this lane.