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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

ARANTZA ESPINOZA, CASE NO.

 Plaintiff,

vs.

1220 COLLINS AVENUE, LLC., a Foreign Limited Liability Company

D/B/A THE WEBSTER

Defendant.

____________________________________________/

COMPLAINT FOR DECLARATORY AND

INJUNCTIVE RELIEF, AND JURY TRIAL DEMAND

 Plaintiff, ARANTZA ESPINOZA, through undersigned counsel, sues Defendant, 1220 

COLLINS AVENUE, LLC., a Foreign Limited Liability Company d/b/a THE WEBSTER

(hereinafter referred to as “THE WEBSTER”), for declaratory and injunctive relief, and damages, 

and alleges as follows:

1) This action is brought under Title III of the Americans with Disabilities Act (“ADA”), that 

is codified in 42 U.S.C. §§12181-12189. 

2) This action is also brought pursuant to 28 C.F.R. Part 36.

3) This Court has jurisdiction over this case based on federal question jurisdiction, as provided 

in 28 U.S.C. §1331 and the provisions of the ADA.

4) Furthermore, because this Court has jurisdiction over the ADA claim, the Court has 

supplementary jurisdiction over Plaintiff’s common law tort claim pursuant to 28 U.S.C. §1367.

5) Plaintiff is sui juris, and she is disabled as defined by the ADA and ADA Amendments Act 

of 2008, 42 U.S.C. §12101 (“ADAAA”).

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6) Defendant, THE WEBSTER, is a foreign limited liability company authorized to do 

business and doing business in the State of Florida.

7) Defendant, THE WEBSTER, is a company that sells men’s and women’s clothing, bags, 

shoes, accessories, jewelry, skin care, makeup, fragrance, hair products, body lotions and oils, 

soap, body wash, home décor and kitchen essentials. There is a retail location in Miami-Dade 

County. 

8) Plaintiff seeks declaratory and injunctive relief pursuant to 28 U.S.C. §§ 2201 and 2202.

9) Plaintiff desires to prevent discrimination and demands equal access to Defendant’s 

internet website to purchase stripe socks in white and dusty blue.

10) Plaintiff also seeks declaratory and injunctive relief for trespass against the Plaintiff’s 

computer. The computer is Plaintiff’s personal property, and a claim for trespass attached to same.

11) The Defendant is also liable for compensatory damages to Plaintiff as a result of the 

trespass to Plaintiff’s personal property.

12) The remedies provided under common law for trespass are not exclusive, and same may 

be sought in connection with suits brought under the ADA.

13) Venue is proper in the Southern District of Florida, Miami-Dade Division, since all 

events, actions, injuries, and damages complained of herein occurred in the Southern District of 

Florida.

14) Furthermore, Plaintiff is a resident of Miami-Dade County which falls within the Miami 

Division of the Southern District of Florida.

15) At all relevant times, Plaintiff is and was visually impaired and has Leber Congenital 

Amaurosis since birth that substantially impairs Plaintiff’s vision.

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16) Plaintiff’s visual impairment interferes with her day-to-day activities and causes 

limitations in visualizing their environment. As such, Plaintiff is a member of a protected class 

under the ADA, 42 U.S.C. § 12102(1) - (2), the regulations implementing the ADA set forth at 28 

CFR §§ 36.101, et seq., and in 42 U.S.C. 3602, §802(h). 

17) Plaintiff regularly uses the computer, but she needs the assistance of special software for 

visually impaired persons. The software that she uses is screen reader software that is readily 

available commercially.

18) Defendant is a private entity which owns and operates retail locations. The stores are 

open to the public, and each of Defendant’s locations is defined as a “public accommodation" 

within the meaning of Title III of the ADA because Defendant is a private entity which owns 

and/or operates “[A] bakery, grocery store, clothing store, hardware store, shopping center, or 

other sales or rental establishment,” per 42 U.S.C. §12181(7)(E) and 28 C.F.R. §36.104(2).

19) Defendant’s website is a place of public accommodation per 42 U.S.C. Section 

12181(7)(E) because it’s an extension of Defendant’s brick and mortar stores. The public is able 

to, among other things, view the products available at defendant’s locations, purchase clothing, 

bags, shoes, accessories, jewelry, skin care, makeup, fragrance, hair products, body lotions and 

oils, soap, body wash, home décor and kitchen essentials through defendant’s website, subscribe 

to Defendant’s newsletter, contact a digital stylist, create an account and register to track orders, 

create a wish list, and learn the story behind Defendant’s brand, and join The Webster Elite and 

gain VIP access for rewards. 

20) Since the Defendant’s website is a public accommodation, it must comply with the 

requirements of the ADA. The website cannot discriminate against individuals with disabilities. 

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21) Plaintiff is a customer of Defendant who is and was interested in purchasing socks 

through Defendant’s website and at Defendant’s stores and visiting Defendant’s brick and mortar 

locations. 

22) Plaintiff is not able to visit the physical locations without the assistance of a family 

member or caretaker, so the ability to purchase merchandise on Defendant’s website for delivery 

to her home is important to her as an alternative when she is not able to visit the Defendant’s stores.

23) The website also services Defendant’s physical stores by providing information on its 

brand, subscribe to Defendant’s newsletter, contact a digital stylist, create an account and register 

to track orders, create a wish list, and learn the story behind Defendant’s brand, join The Webster 

Elite and gain VIP access for rewards, and other information that Defendant is interested in 

communicating to its customers about its physical locations.

24) Since the website allows the public the ability to view the products available at 

defendant’s locations, purchase clothing, bags, shoes, accessories, jewelry, skin care, makeup, 

fragrance, hair products, body lotions, home décor, kitchen essentials and other items, through 

defendant’s website,subscribe to Defendant’s newsletter, contact a digital stylist, create an account 

and register to track orders, create a wish list, and learn the story behind Defendant’s brand, and 

join The Webster Elite and gain VIP access for rewards, the website is an extension of, and 

gateway to, Defendant’s physical stores. By this nexus, the website is characterized as an 

intangible service, privilege and advantage provided by a place of public accommodation as 

defined under the ADA, and thus an extension of the services, privileges and advantages made 

available to the general public by Defendant through its retail brick and mortar stores.

25) Because the public can view and purchase Defendant’s merchandise that is also offered 

for sale by Defendant at its physical stores, subscribe to Defendant’s newsletter, contact a digital 

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stylist, create an account and register to track orders, create a wish list, and learn the story behind 

Defendant’s brand, and join The Webster Elite and gain VIP access for rewards the website is an 

extension of and gateway to the physical stores, which are places of public accommodation 

pursuant to 42 U.S.C. § 12181(7)(E). As such, the website, as an intangible service, privilege and 

advantage of Defendant’s brick and mortar locations, must be fully accessible and in compliance 

with the ADA, must not discriminate against individuals with disabilities, and must not deny full 

and equal enjoyment of the same services, privileges and advantages afforded to the general public 

both online and at the physical locations.

26) At all times material hereto, Defendant was and still is an organization owning and 

operating the website located at https://thewebster.us/ Since the website is open through the 

internet to the public as an extension of the retail stores, by this nexus the website is an intangible 

service, privilege and advantage of Defendant’s brick and mortar locations, and Defendant has 

subjected itself and the associated website it created and maintains to the requirements of the ADA.

27) Plaintiff is and/or has been a customer who is interested in patronizing, and intends to 

patronize, Defendant’s physical stores, and purchase Defendant’s merchandise, sign up for 

Defendant’s newsletter and create an account through the website and at Defendant’s physical 

stores.

28) The opportunity to shop Defendant’s merchandise from her home is an important 

accommodation for Plaintiff because traveling outside of the home as a visually disabled individual 

is often a difficult, hazardous, frustrating, confusing, and frightening experience. Defendant has 

not provided its business information in any other digital format that is accessible for use by blind 

and visually disabled individuals using screen reader software.

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29) Like most consumers, Plaintiff accesses numerous websites at a time to compare 

merchandise and prices. Plaintiff may look at several dozens of sites to compare features and 

prices.

30) During the months of May and June, 2022, Plaintiff attempted on several occasions to 

utilize the website to browse through the merchandise to educate herself as to the merchandise and 

with the intent to make a purchase through the website or at one of Defendant’s physical stores.

31) Places of public accommodation are not just brick-and-mortar structures. The United 

States Department of Justice and the binding case law increasingly recognize that private entities 

are providing goods and services to the public through websites that operate as places of public 

accommodation under Title III.

32) Defendant is required to make reasonable accommodations to its websites for individuals 

with disabilities to allow them to participate in web-based promotions and obtain goods or services 

via the Internet just as sighted persons are able to do.

33) Plaintiff utilized Chrome Vox (“Screen Reader Software”) to attempt to purchase clothing 

on Defendant’s website. However, the Plaintiff was not able to freely and fully use Defendant’s 

website because it contains access barriers that make it inaccessible to persons with disabilities, 

and for which there is no reasonable accommodation for the Plaintiff.

34) A person who can see can enjoy the benefits and privileges provided by Defendant’s 

website that include, but are not limited to viewing the products available at defendant’s locations, 

purchasing clothing, bags, shoes, accessories, jewelry, skin care, makeup, fragrance, hair products, 

body lotions and oils, soap, body wash, home décor and kitchen essentials, through defendant’s 

website,subscribe to Defendant’s newsletter, contact a digital stylist, create an account and register 

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to track orders, create a wish list, and learn the story behind Defendant’s brand, and join The 

Webster Elite and gain VIP access for rewards.

35) A person who cannot see, like the Plaintiff in this case, cannot go to Defendant’s website 

and avail themselves of the same privileges. Thus, the Plaintiff has suffered discrimination due to 

Defendant’s failure to provide a reasonable accommodation for Plaintiff’s disability.

36) The Department of Justice has provided useful guidance regarding website accessibility 

under the ADA, and the binding and persuasive case law in this district has applied the Web 

Content Accessibility Guidelines (“WCAG”) 2.0 or 2.1 to determine accessibility. 

37) Defendant’s website does in fact fail the following WCAG 2.0-AA Compliance standards 

and it does not provide sufficient alternatives to serve the equivalent purpose:

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: The ‘Combo Boxes’ for selecting a state throughout the site do not read 

options as user cycles through them (video). They should work like this example shown 

on this page. In instances when the options presented in the dropdown are unfamiliar to 

the user, not having them read out loud as one cycles through them makes selecting the 

desired option difficult – one must select each individual option to get it read.

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: Within the product information section, the link for learning more about 

interest free payments (Klarna) is not fully described in an audible format to the user, 

rendering the option unavailable (video).

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

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Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: Within the checkout process tool tip for phone number is not fully described 

in an audible format to the user (video).

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: Within the checkout process the check box for Join our SMS list is not fully 

described in an audible format to the user, rendering the option unavailable (video).

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

38) Furthermore, Defendant’s website does not contain accessibility assistance that would 

direct a visually impaired person like the Plaintiff to someone who she can contact for assistance, 

questions, or concerns.

39) Thus, Defendant has not provided full and equal enjoyment of the services, facilities, 

privileges, advantages, and accommodations provided by and through the website, in 

contravention of the ADA. 

40) On information and belief, Defendant is, and at all times has been, aware of the barriers 

to its website which prevent individuals with disabilities who are visually impaired from 

comprehending the information within same, and is also aware of the need to provide access to all 

persons who visit its site. 

41) Plaintiff has no plain, adequate, or complete remedy at law to redress the wrongs alleged 

in this Complaint, such that this suit for declaratory judgment and injunctive relief is her only 

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means to secure adequate and complete redress from Defendant’s discriminatory practices in 

connection with use of its website.

42) Notice to Defendant is not required because of Defendant’s failure to cure the violations. 

43) Enforcement of Plaintiff’s rights under the ADA is right and just pursuant to 28 U.S.C. 

§§ 2201 and 2202.

44) Plaintiff has retained the undersigned attorneys to represent her in this case, and has 

agreed to pay them a reasonable fee for their services.

COUNT I – VIOLATION OF THE ADA

45) Plaintiff realleges paragraphs 1 through 44 as if set forth fully herein.

46) Defendant owns and operates the https://thewebster.us/ website, and is a public 

accommodation subject to the ADA pursuant to 42 U.S.C. §12181(7)(E).

47) Defendant’s website is inaccessible to persons with disabilities like the Plaintiff, who is 

visually impaired. Plaintiff was not able to enjoy full and equal access to the information and 

services that Defendant has made available to the public on its website, in violation of 42 U.S.C. 

§12101. et seq, and as prohibited by 42 U.S.C. §12182 et seq.

48) Defendant’s website is not in compliance with the ADA.

49) Defendant has made no reasonable accommodation for Plaintiff’s disability. 

50) A cursory review of a portion of the Defendant’s website revealed that the website is not 

accessible to persons like the Plaintiff that are visually impaired as required by law and for which 

there is no sufficient alternative on Defendant’s website, including:

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: The ‘Combo Boxes’ for selecting a state throughout the site do not read 

options as user cycles through them (video). They should work like this example shown 

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on this page. In instances when the options presented in the dropdown are unfamiliar to 

the user, not having them read out loud as one cycles through them makes selecting the 

desired option difficult – one must select each individual option to get it read.

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: Within the product information section, the link for learning more about 

interest free payments (Klarna) is not fully described in an audible format to the user, 

rendering the option unavailable (video).

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: Within the checkout process tool tip for phone number is not fully described 

in an audible format to the user (video).

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

Violation: Labels or instructions are not provided when content requires user input.

Note/Proof: Within the checkout process the check box for Join our SMS list is not fully 

described in an audible format to the user, rendering the option unavailable (video).

Applicable WCAG 2.1 Standard at Issue: Standard 3.3.2 Labels or Instructions (Level A).

Nature of the Violation: required by WCAG 2.1’s Standard 3.3.2 Labels or Instructions.

51) Due to Defendant’s failure to provide an ADA compliant website, the Plaintiff has been 

injured since she has been denied full access to Defendant’s website.

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52) As a result, Plaintiff is entitled to injunctive relief pursuant to 42 U.S.C. §12133 and 28 

C.F.R. §36.303 to correct the inaccessibility that leads to discrimination against visually impaired 

persons.

WHEREFORE, Plaintiff requests entry of judgment in her favor and against Defendant for the 

following relief:

A. A declaration that Defendant’s website is in violation of the ADA;

B. An Order requiring Defendant, by a date certain, to update its website, and continue 

to monitor and update its website on an ongoing basis, to remove barriers in order that individuals 

with visual disabilities can access, and continue to access, the website and effectively communicate 

with the website to the full extent required by Title III of the ADA;

C. An Order requiring Defendant, by a date certain, to clearly display the universal 

disabled logo within its website, wherein the logo [1] would lead to a page which would state 

Defendant’s accessibility information, facts, policies, and accommodations. Such a clear display 

of the disabled logo is to ensure that individuals who are disabled are aware of the availability of 

the accessible features of the website;

D. An Order requiring Defendant, by a date certain, to provide ongoing support for web 

accessibility by implementing a website accessibility coordinator, a website application 

accessibility policy, and providing for website accessibility feedback to insure compliance thereto.

E. An Order directing Defendant, by a date certain to evaluate its policies, practices and 

procedures toward persons with disabilities, for such reasonable time to allow Defendant to 

undertake and complete corrective procedures to its website;

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F. An Order directing Defendant, by a date certain, to establish a policy of web 

accessibility and accessibility features for its website to insure effective communication for 

individuals who are visually disabled;

G. An Order requiring, by a date certain, that any third-party vendors who participate on 

Defendant’s website to be fully accessible to the visually disabled;

H. An Order directing Defendant, by a date certain and at least once yearly thereafter, to 

provide mandatory web accessibility training to all employees who write or develop programs or 

code for, or who publish final content to, Defendant’s website on how to conform all web content 

and services with ADA accessibility requirements and applicable accessibility guidelines;

I. An Order directing Defendant, by a date certain and at least once every three months 

thereafter, to conduct automated accessibility tests of its website to identify any instances where 

the website is no longer in conformance with the accessibility requirements of the ADA and any 

applicable accessibility guidelines, and further directing Defendant to send a copy of the twelve 

(12) quarterly reports to Plaintiff’s counsel for review.

J. An Order directing Defendant, by a date certain, to make publicly available and 

directly link from its website homepage, a statement of Defendant’s Accessibility Policy to ensure 

the persons with disabilities have full and equal enjoyment of its website and shall accompany the 

public policy statement with an accessible means of submitting accessibility questions and 

problems.

K. An award to Plaintiff of her reasonable attorney’s fees and costs pursuant to in 42 

U.S.C. §§12181-12189, and pursuant to such other laws and statutes that may apply, and further 

relief as the Court deems just and equitable. 

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[1]

COUNT II – TRESPASS

53) Plaintiff realleges paragraphs 1 through 44 as if set forth herein. 

54) Defendant’s website contains software analytics. Since Plaintiff has navigated 

Defendant’s website as stated herein, Plaintiff’s computer and the personal information and 

browsing history stored therein, has suffered a trespass by Defendant.

55) Plaintiff never consented to and was unaware that Defendant’s website was placing 

software on her computer. 

56) Defendant committed common law trespass in violation of Florida law against Plaintiff 

because Plaintiff did not consent to the placement of tracking and information securing software 

on her personal computer, which was done without her knowledge and consent.

57) Defendant’s trespass has damaged Plaintiff by affecting the condition and value of her 

computer. 

58) On its website, Defendant has an internet privacy policy section that can only be accessed 

by clicking a barely visible section at the bottom of the page called “Cookies Policy”, providing 

that they use cookies and similar technologies to collect a consumer’s information and they obtain 

non-public information from their users for their own advertising and marketing purposes by 

placing software on its website that collects a website user’s preferences and internet browsing 

habits as follows:

5.1 Cookies

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Cookies are small pieces of information sent by a web server to a web browser, which 

allows the server to uniquely identify the browser on each page. We use cookies to 

collect information and store your online preferences.

For example, cookies that are inserted into web pages allow the following actions, 

depending on the case:

To record the last page visited by the User before entering or just after entering the 

website;

To record the date, time and duration of the visit;

To record the pages viewed;

To automatically authenticate the User’s login without him having to enter his login 

credentials at each visit;

To identify system information (language, country, operating system, browser etc.).

We use the following categories of cookies on our Website:

(a) STRICTLY NECESSARY COOKIES These cookies are essential in order to enable 

you to move around the website and use its features. Without these cookies, services you 

have asked for such as remembering your login details or shopping basket items cannot 

be provided.

(b) PERFORMANCE COOKIES These cookies collect anonymous information on how 

you use our Website. For example, we use Google Analytics cookies to help us understand 

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how customers arrive at our site, browse or use our site and highlight areas where we can 

improve areas such as navigation, shopping experience and marketing campaigns. The data 

stored by these cookies does not show personal details from which your individual identity 

can be established. You may opt into these cookies using your browser settings but it may 

affect the performance of our Website.

(c) FUNCTIONALITY COOKIES These cookies remember choices you make such as the 

country you visit our website from, language and search parameters such as size, colour or 

product line. These can then be used to provide you with an experience more appropriate 

to your selections and to make the visits more tailored and pleasant. The information these 

cookies collect may be anonymized and they cannot track your browsing activity on other 

websites. You may opt into these cookies using your browser settings but it may affect the 

functionality of our Website.

(d) TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect 

information about your browsing habits in order to make advertising more relevant to you 

and your interests. They are also used to limit the number of times you see an advert as 

well as help measure the effectiveness of an advertising campaign. The cookies are usually 

placed by third party advertising networks. They remember the websites you visit and that 

information is shared with other parties such as advertisers. For example, we use third party 

companies to provide you with more personalised adverts when visiting other websites. 

You may opt-in to these cookies using your browser settings.

5.2 How to prevent cookies from being installed?

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If you want to delete any cookies that are already on your computer, you can configure 

your Web browser:

– Google Chrome: Settings → Show advanced settings → Content settings → Cookies / 

All cookies and site data → Click on Remove All to remove the cookies.

– Firefox: Tools → Options → Privacy → Cookies → Show Cookies → Remove All 

Cookies

– Opera: Tools → Preferences → “Advanced” tab → “Cookies” heading → Click on 

“Manage cookies” → Delete the Cookies one by one

– Internet Explorer: Tools → Settings → Options then under History, click on Select, 

select the Cookies checkbox → Delete

– Safari: Open Safari → Click on Safari → Click on Reset Safari → Check the Empty the 

cache checkbox → Check the Remove all cookies checkbox → Click on the Reset button 

at the bottom right.

Information on deleting or controlling cookies is available at www.AboutCookies.org.

Please note that by deleting our cookies or disabling future cookies you may not be able 

to access certain areas or features of our Website.

For other third party cookies relating to behavioural advertising, please go 

to www.aboutads.info

59) Due to Plaintiff’s disability, she could not understand Defendant’s website and she could 

not give informed consent to Defendant’s installation of data and information tracking software 

on her computer. Defendant also could not give informed consent to Defendant’s collection of her 

browsing history and the placement of analytics on her computer.

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60) Thus, Plaintiff has no adequate remedy at law to redress Defendant’s knowing and 

reckless disregard for Plaintiff’s right to exclude others from her computer and determine which 

programs should be installed and operated on her computer.

WHEREFORE, Plaintiff demands judgment against Defendant for Plaintiff’s damages, interest, 

costs, and such further relief as the Court deems just and equitable.

Request for Jury Trial

61) Plaintiff requests a jury trial.

Submitted by:

Mendez Law Offices, PLLC

Attorneys for Plaintiff

P.O. BOX 228630

Miami, Florida 33172

Telephone: 305.264.9090

Facsimile: 1-305.809.8474

Email:info@mendezlawoffices.com

By: /s/ 

DIEGO GERMAN MENDEZ, ESQ.

FL BAR NO.: 52748

Adams & Associates, P.A.

Attorneys for Plaintiff

6500 Cowpen Road, Suite 101

Miami Lakes, FL 33014

Telephone: 786-290-1963

Facsimile: 305-824-3868

Email: radamslaw@bellsouth.net

By: /s/ 

RICHARD J. ADAMS, ESQ.

FL BAR NO.: 770434

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