Sealed forensic record · Report #708

**ADA Title III Web Accessibility — Consumer Platform** This matter alleges violations of the Americans with Disabilities Act Title III, the Unruh Civil Rights Act, and New York State Human Rights Law under the framework established in *Robles v. Domino's Pizza, Inc.*, 9th Cir. The defendant, a consumer-facing platform, maintained a website with accessibility barriers that prevented users with disabilities from equal access to goods and services. The site captured 15 accessibility violations across scanned pages. Third-party tracking infrastructure fired 47 times during the audit. The defendant made environmental claims including: "plastic products with plastic waste removed from the ocean," "plastic products with plastic waste removed from the ocean and giving it a second life," "RSP is ISO 14001 Registered," "RSP offers manufacturing materials from leading ocean plastics suppliers that utilize a verified supply chain from the world's oceans, rivers and shores," "RSP has molded over 50 metric tons of recycled ocean-bound plastic," and "This is equivalent to saving about 10,000 gallons of gasoline or the carbon sequestered by more than 75 acres of trees in just one year." Sealed PDF: 20 screenshots with chain-of-custody seals; ~15–25 pages total.