Sealed forensic record · Report #710

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 Platform** A consumer-facing digital platform faces exposure under Title III of the Americans with Disabilities Act, *Robles v. Domino's Pizza, Inc.*, 9th Cir. (2019), the California Unruh Civil Rights Act, and New York State Human Rights Law for failure to provide equal access to goods and services online. The platform's website contains 8 accessibility violations across scanned pages. The site also fires 621 third-party tracker requests during user navigation. Captured representations include: "1g of clinically proven creatine per chew"; "Enhances cognitive function & ATP production"; "Steadier energy through glucose regulation*"; "Aids recovery and reduces inflammation from training or stress"; "Independently tested to verify safety, quality, and results"; "100% of NFL teams using Momentous products in their locker rooms"; and "The U.S. Department of Defense has awarded 11* innovation and research contracts to Momentous." The sealed PDF contains 49 screenshots with chain-of-custody documentation across 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 2026-06-09).
No prior plaintiff-class filing found against this defendant in this lane.