Sealed forensic record · Report #709

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: Washington

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 Platform** A consumer-facing e-commerce platform faces potential liability under Title III of the Americans with Disabilities Act, the Robles v. Domino's framework (9th Cir.), California's Unruh Civil Rights Act, and New York State Human Rights Law for barriers to digital access. The site's product catalog and checkout pathway present documented accessibility violations affecting screen-reader users and keyboard navigators. Automated scanning identified 13 accessibility violations across the site's primary user pathways. The platform loads 70 third-party trackers, including analytics and advertising pixels, without corresponding accessibility accommodations. Product representations captured include "100% BIODEGRADABLE DENTAL FLOSS REFILLS (PACKAGE-FREE)," "ALCOHOL-FREE WITCH HAZEL REFILL," "TOOTHPASTE TABLETS REFILL (FLUORIDE-FREE)," "SEVEN SEAS NON-TOXIC NAIL POLISH," "NON-TOXIC NAIL POLISH," "BABY AND KIDS SUNSCREEN STICK - 30 SPF," "FACE MOISTURIZER WITH SPF REFILL | 30 SPF," and "FACE MOISTURIZER WITH SPF 2OZ BOTTLE | 30 SPF." Evidence chain: 30 screenshots with forensic seals, sealed PDF (~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 2026-06-09).
No prior plaintiff-class filing found against this defendant in this lane.