Sealed forensic record · Report #698

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: New York

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 — Consumer Platform** This matter alleges violations of the Americans with Disabilities Act Title III and the Unruh Civil Rights Act arising from barriers to digital access on a consumer-facing e-commerce platform, following *Robles v. Domino's Pizza, Inc.*, 9th Cir. (2019), and applicable New York State Human Rights Law standards. The defendant, a mid-market consumer products platform, presented 11 accessibility violations across scanned pages. The site captured 15 verbatim product representations, including "RECYCLABLE PAPER BASED REFILLS," "FREE FROM HARSH CHEMICALS," "Recyclable paper-based refills + forever bottles," "Free from the harsh stuff," "ETERNAL ALUMINUM BOTTLES," "Our 32 oz detergent comfortably washes 64 loads," "Each laundry detergent refill uses eco friendly, paper-based, 100% recyclable packaging," and "Our hypoallergenic, sensitive skin-safe detergent." No third-party trackers were detected. Nine screenshots with chain-of-custody seals document the violations. 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.