Sealed forensic record · Report #696

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

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 faces potential liability under Title III of the Americans with Disabilities Act, *Robles v. Domino's Pizza, Inc.*, 9th Cir. (2019), the California Unruh Civil Rights Act, and New York State Human Rights Law for barriers to digital access. The website contains 12 accessibility violations across scanned pages, preventing users with disabilities from navigating and using core functionality. Third-party tracking infrastructure (253 tracker fires) operates throughout the site without apparent accommodation for assistive technologies. No verbatim representations were captured during this run. Findings remain unclassified pending further analysis. Evidence chain includes 13 screenshots with forensic seals. Sealed PDF spans 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.