Sealed forensic record · Report #812

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: Georgia

Nat'l classScope varies — ADA Title III

ArbitrationClass-viable — browsewrap, likely unenforceable

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. Case theory: Title III of the Americans with Disabilities Act, *Robles v. Domino's Pizza, Inc.* (9th Cir. 2019), California Unruh Civil Rights Act, New York State Human Rights Law. Agent captured 12 verbatim representations, 180 third-party tracker fires, and 21 accessibility violations across ~15–25 pages. Representations include: "You can return the product in 60 days if you are not 100% satisfied"; "Celebrating 37 Years!"; "all of our encasings are made in our own sewing plant in North Georgia"; "we have special processes to be sure our encasings, including seams and zippers, don't leak"; "we thoroughly inspect every single encasing we make"; "most weekday orders received by 1:00PM Eastern Time are shipped that same day"; "60-day 100% satisfaction guarantee on all of our products"; "we use recognized independent testing laboratories to test the effectiveness of our encasings and other products." Third-party tracker fire count: 180. Accessibility violation count: 21. Chain-of-custody: 34 sealed screenshots, 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 2026-06-11).
No prior plaintiff-class filing found against this defendant in this lane.