Sealed forensic record · Report #705

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: Utah

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 defendant operates a website with documented accessibility barriers. Under *Robles v. Domino's* (9th Cir.) and the Unruh Civil Rights Act, websites must provide equal access to individuals with disabilities. This run identified 8 accessibility violations across the scanned pages, along with 57 third-party tracker fires that may implicate data-collection practices during user navigation. No verbatim representations were captured during this run. Findings rest on technical audit results: accessibility gaps and tracker activity logged across 15 screenshots with chain-of-custody seals. Sealed PDF: ~15–25 pages, full chain-of-custody documentation included.

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.