Sealed forensic record · Report #703

**ADA Title III Web Accessibility — Consumer-Facing Platform** This matter arises under Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq., the *Robles v. Domino's Pizza* framework (9th Cir. 2019), the California Unruh Civil Rights Act, Cal. Civ. Code § 51, and the New York State Human Rights Law, N.Y. Exec. Law § 296. A consumer-facing e-commerce platform failed to maintain accessible digital infrastructure, preventing users with disabilities from independently accessing and purchasing products. Nine accessibility violations were identified across the scanned domain. The defendant made material representations including "Up to 15% savings on premium cuts vs. grocery stores," "[DEFENDANT] pricing includes free protein for 12 months with the value of up to $422," "100% Grass-Fed, Pasture-Raised," "Wild-Caught," "Organic, Free-Range," "100% sustainably harvested seafood," "No antibiotics or added hormones, ever," and "Free of over 200 banned ingredients." These product and pricing claims were presented on pages that lacked sufficient accessibility controls. No third-party tracking infrastructure was detected. Eight screenshots with chain-of-custody seals document the violations across approximately 15–25 pages in the sealed PDF.