Sealed forensic record · Report #2309

**ADA Title III Web Accessibility — Consumer Platform** This case invokes Title III of the Americans with Disabilities Act, the *Robles v. Domino's* standard (9th Cir.), the Unruh Civil Rights Act, and New York State Human Rights Law. The defendant is a consumer-facing digital platform operating without conformance to WCAG 2.1 accessibility standards. The platform exhibits 8 accessibility violations across scanned pages. Third-party tracking infrastructure fired 20 times during the audit, creating additional barriers to assistive-technology users. The defendant's representations include: "Carmine E120 is approved by the FDA as a color additive for food and cosmetic use"; "excellent stability against heat and light"; "delivers a broad range of shades, from bright pinks to deep purples, depending on formulation and pH"; "performs consistently across a pH range of approximately 3.5 to 8"; "Liquid carmine is commonly used in dairy products, beverages, confectionery, sauces, and other aqueous food systems requiring precise dosing and uniform dispers"; "excellent heat and light stability, and reliable performance across a pH range of approximately 3.0 to 12"; "maintains excellent thermal and light stability, and performs reliably within a pH range of 3.5 to 8"; and "excellent heat and light stability." 27 screenshots with forensic chain-of-custody seals; sealed PDF ~15–25 pages.