Josue Paguada – Mars Khaimov Law, PLLC Lawsuits

This profile for Mars Khaimov Law is one in a series of seven for my breakdown of the law firms who most commonly file web accessibility lawsuits.  In each profile, I summarize common and/or repetitive elements found in multiple lawsuits.

Plaintiff(s): Josue Paguada
Plaintiff’s lawyer: Mars Khaimov Law, PLLC

Lawsuit venue: United States District Court Southern District of New York

Legal claim: Defendant has denied Plaintiff’s rights under the Americans with Disabilities Act or ADA because defendant’s website is inaccessible to blind and visually-impaired consumers.

Federal Law: Title III of the ADA, 42 U.S.C. § 12181, et seq., and 28 U.S.C. § 1332
Local Law: New York City Human Rights Law, N.Y.C. Admin. Code § 8-101 et seq., (“NYCHRL”)

Specific claims (summary): lack of alt text, failure to include label element or title attribute for each field, same title elements, broken links (followed by general list alleging that website includes additional barriers blocking full and equal use).


I’m the Chief Accessibility & Legal Officer at eSSENTIAL Accessibility.  We’re an experienced digital accessibility company that provides an all-in-one solution to help clients make their digital assets accessible and prevent demand letters in 2021.

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