   Defendant owns, manages and/or operates the Hotel.      As part of its operations, Defendant provides its customers and the public  reservations services, including, but not limited to, the ability to reserve rooms online via  the Website.      Within the applicable limitations period, Plaintiff visited the Website to identify  the accessible features of the Hotel and its guest rooms to determine whether it met her  accessibility needs.       Plaintiff was unable to independently ascertain the accessible features of the Hotel  and its guest rooms by reference to the Website as required by the ADA.  42 U.S.C. §  12182 et seq. and 28 C.F.R. §   36.302(e)(1) et seq. (“ADA Accessibility Standards”).     An investigation performed on Plaintiff’s behalf confirmed the allegations made  by Plaintiff in paragraphs 16 through 17.     The barriers to access on the Website, all encountered by Plaintiff, include but are  not limited to, the following:   a)  The Website fails to disclose the physical barriers to access identified in  the preceding section.  These physical access barriers represent material  elements of the Hotel that do not comply with applicable ADA Standards.   Defendant’s failure to identify them prevents Plaintiff and other  individuals with disabilities from independently determining if the Hotel  meets his or her accessibility needs.  b)  On the homepage of www.choicehotels.com/ohio/cleveland/comfort-inn- hotels/oh167?source=gyxt, there is a general description of the Hotel's  location and features; however, none of the information provided relates to  accessibility as required by Disability Access Laws.  c)  On the homepage there is a section labeled "Amenities" which offers a list  of various amenities that the Hotel provides; however, none of the  information provided relates to accessibility as required by Disability  Access Laws.  d)  On the homepage there is a section labeled "Policies" that offers a list of  the Hotel's various policies; however, there was no information pertaining  to accessibility as required by Disability Access Laws.  e)  Remaining links from the homepage do not contain information regarding  accessibility as required by Disability Access Laws.  e)       When attempting to make a reservation, Plaintiff was unable to book a  room because she was unable to find any information or room option  pertaining to accessibility as required by Disability Access Laws.     Defendant’s failure to modify its policies, practices and procedures to ensure that  individuals with disabilities can make reservations for accessible guest rooms during the  same hours and in the same manner as individuals who do not need accessible rooms is  discriminatory and violates ADA Accessibility Standards.     Plaintiff is a tester in this litigation and a consumer who wishes to access  Defendant’s good and services at the Hotel.  Plaintiff is being deterred from patronizing  the Hotel on particular occasions but intends to return to the Hotel and the Website for  the dual purpose of availing herself of the goods and services offered to the public by the  Hotel and to ensure that Defendant ceases evading its responsibilities under federal law.     However, the lack of accessible reservations services has deterred Plaintiff from  staying at the Hotel.     Plaintiff has been, and in the absence of an injunction will continue to be, injured  by Defendant’s policy and practice of failing to provide accessible reservations services  to persons with disabilities.     Plaintiff brings this action under Rule 23(a) and (b)(2) of the federal rules of civil  procedure and on behalf of herself and the following class: “All individuals with  disabilities who have been, or in the future will be, denied the full and equal enjoyment of  reservations services offered to guests at the Hotel because of the lack of accessible  reservations services through the Website.”     Numerosity: The class described above is so numerous that joinder of all  individual members in one action would be impracticable. The disposition of the  individual claims of the respective class members through this class action will benefit  both the parties and the Court and will facilitate judicial economy.     Typicality:  Plaintiff’s claims are typical of the claims of the members of the  class. The claims of Plaintiff and members of the class are based on the same legal  theories and arise from the same unlawful conduct.     Common Questions of Fact and Law:  There is a well-defined community of  interest and common questions of fact and law affecting members of the class in that they  all have been and/or are being denied their civil rights to full and equal access to, and use  and enjoyment of, Defendant’s goods, services and facilities due to the policies and  practices described above.     Adequacy of Representation:  Plaintiff is an adequate representative of the class  because her interests do not conflict with the interests of the members of the class.  Plaintiff will fairly, adequately, and vigorously represent and protect the interests of the  members of the class and has no interests antagonistic to the members of the class.  Plaintiff has retained counsel who are competent and experienced in the prosecution of  class action litigation, generally, and who possess specific expertise in the context of  litigation under the ADA.     Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because  Defendant has acted or refused to act on grounds generally applicable to the class,  making appropriate both declaratory and injunctive relief with respect to Plaintiff and the  class as a whole.    Plaintiff incorporates by reference the allegations stated in paragraphs “1” through  “29” of this complaint as if fully stated herein.      Plaintiff brings this claim individually and on behalf of the class.     Plaintiff is an individual with a disability under the ADA. 42 U.S.C. §  Violations of 42 U.S.C. §§ 12181, et seq.  