IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

HOLGER FIALLO,

Plaintiff,

v.

ASSA ABLOY INC. dba YALE,

Defendant.

Civil Action No. 

COMPLAINT FOR DECLARATORY 

AND INJUNCTIVE RELIEF

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

HOLGER FIALLO (“Plaintiff”), by and through undersigned counsel, seeks a permanent 

injunction requiring a change in ASSA ABLOY INC. dba YALE’s (“YALE” and “Defendant”) 

corporate policies to cause its Website to become, and remain, accessible to individuals with visual 

disabilities. In support thereof, Plaintiff respectfully asserts as follows:

INTRODUCTION

1. In a September 25, 2018 letter to U.S. House of Representative Ted Budd, U.S. 

Department of Justice Assistant Attorney General Stephen E. Boyd confirmed that public 

accommodations must make the Websites they own, operate, or control equally accessible to 

individuals with disabilities. Assistant Attorney General Boyd’s letter provides:

The Department [of Justice] first articulated its interpretation that the ADA applies 

to public accommodations’ Websites over 20 years ago. This interpretation is 

consistent with the ADA’s title III requirement that the goods, services, privileges, 

or activities provided by places of public accommodation be equally accessible to 

people with disabilities.1

1 See Letter from Assistant Attorney General Stephen E. Boyd, U.S. Department of Justice, 

to Congressman Ted Budd, U.S. House of Representatives (Sept. 25, 2018) (available at 

https://images.cutimes.com/contrib/content/uploads/documents/413/152136/adaletter.pdf) (last 

accessed March 25, 2020).

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2. Plaintiff Fiallo is legally blind. He lost his sight at 18 years old to glaucoma. He 

uses a screen reader to navigate the Internet as well as Windows 10 with JAWS, the Google 

Chrome browser and iPhone 11 pro max with voiceover technology. 

3. Screen reader “software translates the visual internet into an auditory equivalent. 

At a rapid pace, the software reads the content of a webpage to the user.” Andrews v. Blick Art 

Materials, LLC, 17-CV-767, 2017 WL 6542466, at *6 (E.D.N.Y. Dec. 21, 2017) (J. Weinstein).

The screen reading software uses auditory cues to allow a visually impaired user to 

effectively use Websites. For example, when using the visual internet, a seeing user 

learns that a link may be “clicked,” which will bring his to another webpage, 

through visual cues, such as a change in the color of the text (often text is turned 

from black to blue). When the sighted user's cursor hovers over the link, it changes 

from an arrow symbol to a hand.

The screen reading software uses auditory—rather than visual—cues to relay this 

same information. When a sight impaired individual reaches a link that may be 

“clicked on,” the software reads the link to the user, and after reading the text of 

the link says the word “clickable.”...Through a series of auditory cues read aloud 

by the screen reader, the visually impaired user can navigate a Website by listening 

and responding with his keyboard.

Id. at *6-7.

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4. Defendant is a leader in the design, development, manufacture, and distribution of 

locks, handles, and similar products, under its recognized brand Yale.

5. Consumers may purchase Defendant’s products and access other brand-related 

content and services at https://shopyalehome.com (“Website”) the Website Defendant owns, 

operates, and controls.

3

2 See American Foundation for the Blind, Screen Readers, available at

https://www.afb.org/node/16207/screen-readers (last accessed March 25, 2020) (discussing 

screen readers and how they work).

3 YALE Privacy Policy, available at https://www.yalehome.com/en/sitefunctions/privacy-center/ (last accessed March 25, 2020).

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6. In addition to researching and purchasing Defendant’s products and services from 

the comfort and convenience of their homes, consumers may also use Defendant’s Website to

contact customer service by phone and email, sign up to receive product updates, product news, 

and special promotions, review important legal notices like Defendant’s Privacy Policy and Terms 

and Conditions, track online orders, and more.

4

7. Defendant is responsible for the policies, practices, and procedures concerning the 

Website’s development and maintenance.

8. Unfortunately, Defendant denies approximately 8.1 million5 Americans who have 

difficulty seeing access to its Website’s goods, content, and services because the Website is largely 

incompatible with the screen reader programs these Americans use to navigate an increasingly 

ecommerce world.

9. Plaintiff brings this civil rights action against Defendant to enforce Title III of the 

Americans with Disabilities Act, 42 U.S.C. § 12101 et seq. (“Title III”), which requires, among 

other things, that a public accommodation (1) not deny persons with disabilities the benefits of its 

services, facilities, privileges and advantages; (2) provide such persons with benefits that are equal 

to those provided to nondisabled persons; (3) provide auxiliary aids and services—including 

electronic services for use with a computer screen reading program—where necessary to ensure 

effective communication with individuals with a visual disability, and to ensure that such persons 

4 See, e.g., YALE Home Page, available at https://shopyalehome.com/ (last accessed 

March 25, 2020).

5 Press Release, United States Census Bureau, Nearly 1 in 5 People Have a Disability in 

the U.S., Census Bureau Reports Report Released to Coincide with 22nd Anniversary of the ADA

(Jul. 25, 2012), available at 

https://www.census.gov/newsroom/releases/archives/miscellaneous/cb12-134.html (last accessed 

March 25, 2020) (“About 8.1 million people had difficulty seeing, including 2.0 million who 

were blind or unable to see.”).

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are not excluded, denied services, segregated or otherwise treated differently than sighted 

individuals; and (4) utilize administrative methods, practices, and policies that provide persons 

with disabilities equal access to online content.

10. By failing to make its Website available in a manner compatible with computer 

screen reader programs, Defendant, a public accommodation subject to Title III, deprives blind 

and visually-impaired individuals the benefits of its online goods, content, and services—all 

benefits it affords nondisabled individuals—thereby increasing the sense of isolation and stigma 

among these Americans that Title III was meant to redress.

11. Because Defendant’s Website is not and has never been fully accessible, and 

because upon information and belief Defendant does not have, and has never had, adequate

corporate policies that are reasonably calculated to cause its Website to become and remain 

accessible, Plaintiff invokes 42 U.S.C. § 12188(a)(2) and seeks a permanent injunction requiring

Defendant to:

a) Retain a qualified consultant acceptable to Plaintiff (“Web Accessibility 

Consultant”) who shall assist in improving the accessibility of its Website, 

including all third-party content and plug-ins, so the goods and services on the 

Website may be equally accessed and enjoyed by individuals with vision related 

disabilities; 

b) Work with the Web Accessibility Consultant to ensure all employees involved in 

Website and content development be given web accessibility training on a biennial

basis, including onsite training to create accessible content at the design and 

development stages;

c) Work with the Web Accessibility Consultant to perform an automated accessibility 

audit on a periodic basis to evaluate whether Defendant’s Website may be equally 

accessed and enjoyed by individuals with vision related disabilities on an ongoing 

basis; 

d) Work with the Web Accessibility Consultant to perform end-user 

accessibility/usability testing on at least a quarterly basis with said testing to be 

performed by humans who are blind or have low vision, or who have training and 

experience in the manner in which persons who are blind use a screen reader to 

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navigate, browse, and conduct business on Websites, in addition to the testing, if 

applicable, that is performed using semi-automated tools;

e) Incorporate all of the Web Accessibility Consultant’s recommendations within 

sixty (60) days of receiving the recommendations;

f) Work with the Web Accessibility Consultant to create a Web Accessibility Policy 

that will be posted on its Website, along with an e-mail address, instant messenger,

and toll-free phone number to report accessibility-related problems;

g) Directly link from the footer on each page of its Website, a statement that indicates 

that Defendant is making efforts to maintain and increase the accessibility of its 

Website to ensure that persons with disabilities have full and equal enjoyment of 

the goods, services, facilities, privileges, advantages, and accommodations of the 

Defendant through the Website;

h) Accompany the public policy statement with an accessible means of submitting 

accessibility questions and problems, including an accessible form to submit 

feedback or an email address to contact representatives knowledgeable about the 

Web Accessibility Policy;

i) Provide a notice, prominently and directly linked from the footer on each page of 

its Website, soliciting feedback from visitors to the Website on how the 

accessibility of the Website can be improved. The link shall provide a method to 

provide feedback, including an accessible form to submit feedback or an email 

address to contact representatives knowledgeable about the Web Accessibility 

Policy;

j) Provide a copy of the Web Accessibility Policy to all web content personnel, 

contractors responsible for web content, and Client Service Operations call center 

agents (“CSO Personnel”) for the Website;

k) Train no fewer than three of its CSO Personnel to automatically escalate calls from 

users with disabilities who encounter difficulties using the Website. Defendant

shall have trained no fewer than 3 of its CSO personnel to timely assist such users 

with disabilities within CSO published hours of operation. Defendant shall 

establish procedures for promptly directing requests for assistance to such 

personnel including notifying the public that customer assistance is available to 

users with disabilities and describing the process to obtain that assistance;

l) Modify existing bug fix policies, practices, and procedures to include the 

elimination of bugs that cause the Website to be inaccessible to users of screen 

reader technology;

m) Plaintiff, his counsel, and their experts monitor the Website for up to two years after 

the Mutually Agreed Upon Consultant validates the Website are free of 

accessibility errors/violations to ensure Defendant has adopted and implemented 

adequate accessibility policies. To this end, Plaintiff, through his counsel and their 

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experts, shall be entitled to consult with the Web Accessibility Consultant at their 

discretion, and to review any written material, including but not limited to any 

recommendations the Website Accessibility Consultant provides Defendant. 

12. Web-based technologies have features and content that are modified on a daily, and 

in some instances an hourly, basis, and a one time “fix” to an inaccessible Website will not cause 

the Website to remain accessible without a corresponding change in corporate policies related to 

those web-based technologies. To evaluate whether an inaccessible Website has been rendered 

accessible, and whether corporate policies related to web-based technologies have been changed 

in a meaningful manner that will cause the Website to remain accessible, the Website must be 

reviewed on a periodic basis using both automated accessibility screening tools and end user 

testing by disabled individuals.

JURISDICTION AND VENUE

13. The claims alleged arise under Title III such that this Court’s jurisdiction is invoked 

pursuant to 28 U.S.C. § 1331 and 42 U.S.C. § 12188.

14. Defendant participates in the economic life of Illinois by clearly performing 

business over the Internet. Through its Website, Defendant entered into contracts for the sale of its 

products and services with residents of Illinois. These online sales contracts involve, and indeed 

require, Defendant’s knowing and repeated transmission of computer files over the Internet. See

Hetz v. Aurora Med. Ctr. of Manitowoc Cnty., No. 06-C-636, 2007 U.S. Dist. LEXIS 44115, at *6 

(E.D. Wis. June 18, 2007).

15. As described in additional detail below, Plaintiff was injured when he attempted to 

access Defendant’s Website from his home in this District but encountered barriers that denied his 

full and equal access to Defendant’s online goods, content, and services.

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16. Venue in this District is proper under 28 U.S.C. § 1391(b)(2) because this is the 

judicial district in which a substantial part of the acts and omissions giving rise to Plaintiff’s claim 

occurred. 

PARTIES

17. Plaintiff Fiallo is and, at all times relevant hereto, has been a resident of Chicago, 

Illinois. Plaintiff is and, at all times relevant hereto, has been legally blind and is therefore a 

member of a protected class under the ADA, 42 U.S.C. § 12102(2) and the regulations 

implementing the ADA set forth at 28 CFR §§ 36.101et seq. 

18. Defendant Yale is an Oregon corporation with its principal place of business at 110 

Sargent Drive, New Haven, CT, 06511.

FACTS APPLICABLE TO ALL CLAIMS

19. While the increasing pervasiveness of digital information presents an 

unprecedented opportunity to increase access to goods, content, and services for people with 

perceptual or motor disabilities, Website developers and web content developers often implement 

digital technologies without regard to whether those technologies can be accessed by individuals 

with disabilities. This is notwithstanding the fact that accessible technology is both readily 

available and cost effective.

DEFENDANT’S ONLINE CONTENT

20. Defendant’s Website allows consumers to research and participate in Defendant’s

services and products from the comfort and convenience of their own homes.

21. The Website also enables consumers to contact customer service by phone and 

instant messenger, find local retailers, sign up to receive product updates, product news, and 

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special promotions, review important legal notices like Defendant’s Privacy Policy and Terms and 

Conditions, track online orders, and more.

22. Consumers may use the Website to connect with Defendant on social media, using 

sites like Facebook, Twitter, Instagram, and YouTube.

HARM TO PLAINTIFF

23. Plaintiff attempted to access the Website from his home in Chicago, Illinois. 

Unfortunately, because of Defendant’s failure to build the Website in a matter that is compatible 

with screen reader programs, Plaintiff is unable to understand, and thus is denied the benefit of, 

much of the content and services he wishes to access on the Website. For example:

a. Defendant’s Website is so constructed that the images on the homepage are 

not labeled. The homepage contains a carousel with seven images that each link to a different 

product on the page, while also highlighting the features. This content is not read and instead all

the user hears is “link” repeated seven times. Furthermore, the “let’s keep in touch” pop-up is not 

given focus and is not announced. 

b. The product color options on Defendant’s Website is not announced. When 

a user navigates to the color selection element, they hear that they need to select a color but none 

of the colors are announced. Instead, “color radio button checked 1 of 3” is announced, but the 

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specific color is only shown onscreen. Screen reader users are not aware that the image color has 

changed, nor do they hear the color name that is displayed in text. 

c. The cart confirmation messages that are automated on Defendant’s Website

are not announced. The confirmation message that shows onscreen when the user adds a product 

to the cart is not announced to the screen reader, rather, focus moves to other elements below the 

items. Therefore, it appears that the button does not work since no confirmation is provided. 

24. These barriers, and others, deny Plaintiff full and equal access to all of the services 

the Website offers, and now deter him from attempting to use the Website. Still, Plaintiff would 

like to, and intends to, attempt to access the Website in the future to research the products and 

services the Website offer, or to test the Website for compliance with the ADA.

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25. If the Website was accessible, i.e. if Defendant removed the access barriers 

described above, Plaintiff could independently research and purchase Defendant’s products and 

access its other online content and services.

26. Though Defendant may have centralized policies regarding the maintenance and 

operation of the Website, Defendant has never had a plan or policy that is reasonably calculated to 

make the Website fully accessible to, and independently usable by, individuals with vision related 

disabilities. As a result, the complained of access barriers are permanent in nature and likely to 

persist.

27. The law requires that Defendant reasonably accommodates Plaintiff’s disabilities

by removing these existing access barriers. Removal of the barriers identified above is readily 

achievable and may be carried out without much difficulty or expense.

28. Plaintiff has been, and in the absence of an injunction will continue to be, injured 

by Defendant’s failure to provide its online content and services in a manner that is compatible 

with screen reader technology.

DEFENDANT’S KNOWLEDGE OF WEBSITE ACCESSIBILITY REQUIREMENTS

29. Defendant has long known that sufficient contrast and skip navigation links are

necessary for individuals with visual disabilities to access its online content and services, and that 

it is legally responsible for providing the same in a manner that is compatible with these auxiliary 

aids.

30. Indeed, the “Department [of Justice] first articulated its interpretation that the ADA 

applies to public accommodations’ Websites over 20 years ago.” As described above, on 

September 25, 2018, Assistant Attorney General Stephen E. Boyd confirmed nothing about the 

ADA, nor the Department’s enforcement of it, has changed this interpretation.

///

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THE PARTIES HAVE NO ADMINISTRATIVE REMEDIES TO PURSUE

31. There is no DOJ administrative proceeding that could provide Plaintiff with Title 

III injunctive relief.

32. While the DOJ has rulemaking authority and can bring enforcement actions in 

court, Congress has not authorized it to provide an adjudicative administrative process to provide 

Plaintiff with relief.

33. Plaintiff alleges violations of existing and longstanding statutory and regulatory 

requirements to provide auxiliary aids or services necessary to ensure effective communication, 

and courts routinely decide these types of effective communication matters.

34. Resolution of Plaintiff’s claims does not require the Court to unravel intricate, 

technical facts, but rather involves consideration of facts within the conventional competence of 

the courts, e.g. (a) whether Defendant offers content and services on its Website, and (b) whether 

Plaintiff can access the content and services.

SUBSTANTIVE VIOLATIONS

COUNT I

Title III of the ADA, 42 U.S.C. § 12181 et seq.

35. The assertions contained in the previous paragraphs are incorporated by reference.

36. Defendant’s Website is a place of public accommodation within the definition of 

Title III of the ADA, 42 U.S.C. § 12181(7).

37. In the broadest terms, the ADA prohibits discrimination on the basis of a disability 

in the full and equal enjoyment of goods and services of any place of public accommodation. 42 

U.S.C. § 12182(a). Thus, to the extent Defendant does not provide Plaintiff with full and equal 

access to its Website, they have violated the ADA.

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38. In more specific terms, Title III of the ADA imposes statutory and regulatory 

requirements to ensure persons with disabilities are not excluded, denied services, segregated or 

otherwise treated differently than other individuals as a result of the absence of auxiliary aids and 

services. 42 U.S.C. § 12182(b)(2)(A); 28 C.F.R. §§ 36.303(a), (c). Under these provisions, public 

accommodations must furnish appropriate auxiliary aids and services that comply with their 

effective communication obligations. Id.

39. Auxiliary aids and services are necessary when their absence effectively excludes 

an individual from participating in or benefiting from a service or fails to provide a like experience 

to the disabled person.

40. Auxiliary aids and services include, but are not limited to, audio recordings, screen 

reader software, magnification software, optical readers, secondary auditory programs, large print 

materials, accessible electronic and information technology, other effective methods of making 

visually delivered materials available to individuals who are blind or have low vision, and other 

similar services and actions. 28 C.F.R. §§ 36.303(b)(2), (4).

41. In order to be effective, auxiliary aids and services must be provided in accessible 

formats, in a timely manner, and in such a way as to protect the privacy and independence of the

individual with a disability. 28 C.F.R. §§ 36.303(c)(1)(ii). To this end, the Ninth Circuit has 

explained, “assistive technology is not frozen in time: as technology advances, [ ] accommodations 

should advance as well.” Enyart v. Nat'l Conference of Bar Examiners, Inc., 630 F.3d 1153, 1163 

(9th Cir. 2011).

42. By failing to provide its Website’s content and services in a manner that is 

compatible with auxiliary aids, Defendant has engaged, directly, or through contractual, licensing, 

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or other arrangements, in illegal disability discrimination, as defined by Title III, including without 

limitation:

(a) denying individuals with visual disabilities opportunities to participate in 

and benefit from the goods, content, and services available on its Website;

(b) affording individuals with visual disabilities access to its Website that is not 

equal to, or effective as, that afforded others;

(c) utilizing methods of administration that (i) have the effect of discriminating 

on the basis of disability; or (ii) perpetuate the discrimination of others who are subject to common 

administrative control;

(d) denying individuals with visual disabilities effective communication, 

thereby excluding or otherwise treating them differently than others; and/or

(e) failing to make reasonable modifications in policies, practices, or 

procedures where necessary to afford its services, privileges, advantages, or accommodations to 

individuals with visual disabilities.

43. Defendant has violated Title III by, without limitation, failing to make its Website’s

services accessible by screen reader programs, thereby denying individuals with visual disabilities 

the benefits of the Website, providing them with benefits that are not equal to those it provides 

others, and denying them effective communication.

44. Defendant has further violated Title III by, without limitation, utilizing 

administrative methods, practices, and policies that allow its Website to be made available without 

consideration of consumers who can only access the company’s online goods, content, and services 

with screen reader programs.

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45. Making its online goods, content, and services compatible with screen reader 

programs does not change the content of Defendant’s Website or result in making the Website

different, but rather enables individuals with visual disabilities to access the Website Defendant

already provides.

46. Defendant’s ongoing violations of Title III have caused, and in the absence of an 

injunction, will continue to cause harm to Plaintiff and other individuals with visual disabilities.

47. Plaintiff’s claims are warranted by existing law or by non-frivolous argument for 

extending, modifying, or reversing existing law or for establishing new law.

48. Pursuant to 42 U.S.C. § 12188 and the remedies, procedures and rights set forth 

and incorporated therein, Plaintiff requests relief as set forth below.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for:

(A) A Declaratory Judgment that at the commencement of this action Defendant was in 

violation of the specific requirements of Title III of the ADA described above, and the relevant 

implementing regulations of the ADA, in that Defendant took no action that was reasonably 

calculated to ensure that its Website was fully accessible to, and independently usable by, 

individuals with visual disabilities;

(B) A permanent injunction pursuant to 42 U.S.C. § 12188(a)(2) and 28 CFR § 

36.504(a) which directs Defendant to take all steps necessary to bring its Website into full 

compliance with the requirements set forth in the ADA, and its implementing regulations, so that 

its Website is fully accessible to, and independently usable by, blind individuals, and which further 

directs that the Court shall retain jurisdiction for a period to be determined to ensure that Defendant

has adopted and is following an institutional policy that will in fact cause them to remain fully in 

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compliance with the law—the specific injunctive relief requested by Plaintiff is described more 

fully in paragraph 11 above.

(C) Payment of actual, statutory, and punitive damages, as the Court deems proper;

(D) Payment of costs of suit; 

(E) Payment of reasonable attorneys’ fees, pursuant to 42 U.S.C. § 12205 and 28 CFR 

§ 36.505, including costs of monitoring Defendant’s compliance with the judgment (see 

Gniewkowski v. Lettuce Entertain You Enterprises, Inc., Case No. 2:16-cv-01898-AJS (W.D. Pa.

Jan. 11, 2018) (ECF 191) (“Plaintiffs, as the prevailing party, may file a fee petition before the 

Court surrenders jurisdiction. Pursuant to Pennsylvania v. Delaware Valley Citizens’ Council for 

Clean Air, 478 U.S. 546, 559 (1986), supplemented, 483 U.S. 711 (1987), the fee petition may 

include costs to monitor Defendant’s compliance with the permanent injunction.”); see also Access 

Now, Inc. v. Lax World, LLC, No. 1:17-cv-10976-DJC (D. Mass. Apr. 17, 2018) (ECF 11) (same);

(F) The provision of whatever other relief the Court deems just, equitable and 

appropriate; and

(G) An Order retaining jurisdiction over this case until Defendant has complied with 

the Court’s Orders.

Dated: March 27, 2020 Respectfully Submitted,

/s/ Benjamin Sweet

Benjamin J. Sweet 

ben@sweetlawpc.com

THE SWEET LAW FIRM, P.C.

1145 Bower Hill Road, Suite 104

Pittsburgh, PA 15243

Phone: (412) 857-5350

Additional Counsel Listed Below

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Jonathan D. Miller

jonathan@nshmlaw.com

NYE, STIRLING, HALE & MILLER, LLP

33 W. Mission Street, Suite 201

Santa Barbara, CA 93101

Phone: (805) 963-2345

Attorneys for Plaintiff Holger Fiallo

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