 Plaintiff Gellatly has visited Defendant’s facilities at 1467 S Arlington Street,  Akron, OH; 716 E Market Street, Akron, OH; 117 S Walnut Street, Ligonier, PA, including within  the last year.  Additionally, Plaintiff Nario-Redmond has visited Defendant’s facilities at 3709 W  Dublin Grandville Road, Columbus, OH; 1467 S Arlington Street, Akron, OH; 716 E Market  Street, Akron, OH; 117 S Walnut Street, Ligonier, PA, including within the last year.  Plaintiffs  experienced unnecessary difficulty and risk at Defendant’s facilities due to excessive slopes in the  purportedly accessible parking spaces and access aisles and because of various other ADA  accessibility violations as set forth in more detail below.    Despite these difficulties, Plaintiff Gellatly plans to return to Defendant’s facilities.   Plaintiff Gellatly will be attending college in Western Pennsylvania this fall and regularly travels  throughout Pennsylvania and Ohio visiting friends and family.  Furthermore, Plaintiff Gellatly  intends to return to Defendant’s facilities to ascertain whether Defendant’s facilities remain in  violation of the ADA.    As a result of Defendant’s non-compliance with the ADA, Plaintiffs’ ability to  access and safely use Defendant’s facilities has been significantly impeded.    Plaintiffs will be deterred from returning to and fully and safely accessing  Defendant’s facilities, however, so long as Defendant’s facilities remain non-compliant, and so  long as Defendant continues to employ the same policies and practices that have led, and in the  future will lead, to inaccessibility at its facilities.    Without injunctive relief, Plaintiffs will continue to be unable to fully and safely  access Defendant’s facilities in violation of her rights under the ADA.    As individuals with a mobility disability who is dependent upon a wheelchair,  Plaintiffs are directly interested in whether public accommodations, like Defendant, have  architectural barriers that impede full accessibility to those accommodations by individuals with  mobility-related disabilities.  II.  Defendant Repeatedly Denies Individuals With Disabilities Full and Equal Access to  its Facilities.    Defendant is engaged in the ownership, management and development of  properties, including shopping centers and restaurants.    As the owner and manager of its properties, Defendant employs centralized  policies, practices and procedures with regard to the design, construction, alteration, maintenance  and operation of its facilities.    On Plaintiffs’ behalf, investigators examined multiple locations owned, controlled,  and/or operated by Defendant, and found the following violations, which are illustrative of the fact  that Defendant implements policies and practices that routinely result in accessibility violations:  a) 3709 W Dublin Grandville Road, Columbus, OH  i.  The surfaces of one or more purportedly accessible parking spaces had  slopes exceeding 2.1%;  ii.  The surfaces of one or more access aisles had slopes exceeding 2.1%; and  iii.  A portion of the route to the store entrance had a cross slope exceeding    The fact that individuals with mobility-related disabilities are denied full and equal  access to numerous of Defendant’s facilities, and the fact that each of these facilities deny access  by way of inaccessible parking facilities, is evidence that the inaccessibility Plaintiffs experienced  is not isolated, but rather, caused by Defendant’s systemic disregard for the rights of individuals  with disabilities.    Defendant’s systemic access violations demonstrate that Defendant either employs  policies and practices that fail to design, construct and alter its facilities so that they are readily  accessible and usable, and/or that Defendant employs maintenance and operational policies and  practices that are unable to maintain accessibility.    As evidenced by the widespread inaccessibility of Defendant’s parking facilities,  absent a change in Defendant’s corporate policies and practices, access barriers are likely to  reoccur in Defendant’s facilities even after they have been remediated.    Plaintiffs bring this class action, pursuant to Rules 23(a) and 23(b)(2) of the Federal  Rules of Civil Procedure, on behalf of themselves and the following nationwide class:  all  wheelchair users who have attempted, or will attempt, to utilize the parking facilities at all  locations within the United States for which Defendant owns and/or controls the parking facilities.    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 this Court, and  will facilitate judicial economy.    Typicality:  Plaintiffs’ claims are typical of the claims of the members of the class.   The claims of Plaintiffs 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 facilities and/or services due to Defendant’s failure to make their facilities fully  accessible and independently usable as above described.    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 Plaintiffs and the Class as a  whole.    I.  Plaintiffs Have Been Denied Full and Equal Access to Defendant’s Facilities.  