MEJICO v. MEDIALAB.AI INC.

• Missing alternative text which presents a problem because an image without alternative text results in an empty link. Alternative Text is invisible code embedded beneath a graphical image on a website.
  Web accessibility requires that Alternative Text be coded with each picture so that a screen reader can
  speak the Alternative Text where a sighted user sees pictures. Alternative Text does not change the
  visual presentation, but instead generates a text box that will pop-up when the mouse moves over the
  picture. The lack of Alternative Text on these graphics prevents screen readers from accurately
  vocalizing a description of the graphics;
• Linked image missing alternative text which presents a
  problem because an image without alternative text results in an empty link. Images that are the only
  thing within a link must have descriptive alternative text. If an image is within a link that contains no
  text and that image does not provide alternative text, a screen reader has no content to present to the
  user regarding the function of the link;
• Spacer image missing alternative text which presents a
  problem because a layout spacer image does not have an alt attribute. Spacer images are used to
  maintain layout. They do not convey content and should be given null/empty alternative text (alt=””)
  so they are not presented to users and are ignored by screen readers;
• Empty or missing form labels
  which presents a problem because, if a form control does not have a properly associated text label, the
  function or purpose of that form control may not be presented to screen reader users. Form labels
  provide visible descriptions and larger clickable targets for form controls;
• Empty links which
  present a problem because a link contains no text. If a link contains no text, the function or purpose of
  the link will not be presented to the user. This can introduce confusion for keyboard and screen reader
  users; and
• Redundant Links where adjacent links go to the same URL address which results in
  additional navigation and repetition for keyboard and screen reader users.

Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.

• For a judgment that Defendant violated Plaintiff’s rights under the Unruh Civil Rights Act, California Civil Code § 51 et seq.
• For a preliminary and permanent injunction requiring Defendant to take the steps necessary to make the Websites readily accessible to and usable by visually-impaired individuals, but Plaintiff hereby expressly limit the injunctive relief to require the Defendant expend no more than $20,000 as the cost of injunctive relief;
• An award of statutory minimum damages of $4,000 per violation pursuant to section 52(a) of the California Civil Code, however, Plaintiff expressly limit the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not to exceed $74,999;
•  For attorneys’ fees and expenses pursuant to all applicable laws including, without limitation, California Civil Code § 52(a); however, Plaintiff expressly limits the total amount of recovery, including statutory damages, attorneys’ fees and costs, and cost of injunctive relief not t  exceed $74,999;
• For pre-judgment interest to the extent permitted by law;
• For costs of suit; and
• For such other and further relief as the Court Deems just and proper.