Mars Khaimov, PLLC is one of the most active plaintiffs’ law firms (if not the most) in ADA website accessibility litigation. The Mars Khaimov law firm is responsible for hundreds of complaints filed in New York federal court.
Plaintiffs represented include Veronica Maddy, Lamar Brown, Andrew Toro, Jasmine Toro, Valerie Dicks, Jenny Hwang, Damon Jones, Miriam Cruz, Josue Paguada, and Jovan Campbell.
Having read through 2023 complaints filed by Mars Khaimov, Esq., the accessibility issues claimed appear to be specific to the defendant’s website. This is in contrast to the boilerplate, templated complaints we’ve seen filed for years in the 2nd circuit.
To prevent future litigation, I highly recommend my course, the ADA Compliance Course.
This course contains step-by-step instructions on how to find (audit) and fix (remediate) the most commonly claimed accessibility issues by plaintiffs’ lawyers (including Mars Khaimov, Esq.). This training is superior to any other web accessibility product or service in the market because the lessons in this course are created from the very same issues that plaintiffs’ lawyers are using as a basis for litigation.
The course is specifically designed as an SOP (step-by-step instructions) for website owners to give to their web team.
You can buy the course now at ADACompliance.net.
Below is a past write-up on a complaint filed by Mars with Josue Paguada as the named plaintiff.
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).