Sealed forensic record · Report #691

**ADA Title III / Web Accessibility** This consumer-facing platform faces potential liability under the ADA Title III, *Robles v. Domino's* (9th Cir.), the Unruh Civil Rights Act, and NY State Human Rights Law for web accessibility barriers. The platform's website contains 15 accessibility violations across scanned pages, preventing users with disabilities from accessing product information and purchasing functionality. The platform makes numerous product claims including "[DEFENDANT] made from exactly two ingredients — water and coffee made from 100% Arabica beans," "[DEFENDANT] made with only three simple, whole-food ingredients: Water, organic almonds, and sea salt," "[DEFENDANT] It's made with 100% recycled plastic," "[DEFENDANT] with just three grams of sugar per serving," "[DEFENDANT] Barista Blends froth, foam, and steam perfectly for all your espresso creations," "[DEFENDANT] Creamy Refreshers are irresistibly refreshing, lower-sugar juice blends," "[DEFENDANT] producing oat and almond milk uses less water and land, and emits less greenhouse gas compared to dairy," and "[DEFENDANT] Our products are made with simple, dairy-free and plant-based ingredients." These representations are inaccessible to screen-reader users and those relying on keyboard navigation. 10 screenshots with chain-of-custody seals document the violations across approximately 15–25 pages in the sealed PDF.