MEJICO v. THE HARTFORD FINANCIAL SERVICES GROUP, INC.

• IDs used in ARIA labels must be unique. This is important because duplicate ARIA IDs are
  common validation errors that may break the accessibility of labels, e.g., form fields, table header
  cells. Unique ID’s differentiate each element from another and prevent invalid markup, wherein only
  the first instant gets acted upon by client-side scripting, or where assistive technologies typically only
  reference the first one accurately;
• Ensure that links with the same accessible name serve a similar
  purpose. This is important because the intention is to help users understand the purpose of each link in
  the content, so they can decide whether they want to follow it. Best practice is that links with the same
  destination would have the same descriptions but links with different purposes and destinations would
  have different descriptions which calls for consistency in identifying components that have the same
  functionality. Because the purpose of a link can be identified from its link text, links can be
  understood they are out of context, such as when the user agent providers a list of all the links on a
  page;
• IDs used in ARIA labels must be unique. This is important because duplicate ARIA IDs are
  common validation errors that may break the accessibility of labels, e.g., form fields, table header
  cells. Unique ID’s differentiate each element from another and prevent invalid markup, wherein only
  the first instant gets acted upon by client-side scripting, or where assistive technologies typically only
  reference the first one accurately;
• Text elements must have sufficient color contrast against the
  background, which presents a problem because Some people with low vision experience low contrast,
  meaning that there aren’t very many bright or dark areas. Everything tends to appear about the same
  brightness, which makes it hard to distinguish outlines, borders, edges, and details. Text that is too
  close in luminance (brightness) to the background can be hard to read. There are nearly three times
  more individuals with low vision than those with total blindness. One in twelve people cannot see the average full spectrum of colors – about 8% of men and 0.4% of women in the US. A person with low
  vision or color blindness is unable to distinguish text against a background without sufficient contrast;
• <li> elements must be contained in a <ul> or <ol>, which is important because for a list to be valid,
  it must have both parent and child elements. Parent elements can either be a set of ul tags or a set of ol
  tags. Child elements must be declared inside of these tags using the li tag. Screen readers notify users
  when they come to a list, and tell them how many items are in a list. Announcing the number of items
  in a list and the current list item helps listeners know what they are listening to, and what to expect as
  they listen to it. If you don’t mark up a list using proper semantic markup in a hierarchy, list items
  cannot inform the listener that they are listening to a list when no parent is indicating the presence of a
  list and the type of list; and
• Certain ARIA roles must contain particular children, which is
  important because for each role, WAI-ARIA explicitly defines which child and parent roles are
  allowable and/or required. ARIA roles missing required child roles will not be able to perform the
  accessibility functions intended by the developer. Assistive technology needs to convey the context to
  the user.

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.