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National Federation of the Blind v. Target

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Citation Edit

National Federation of the Blind v. Target Corp., 452 F.Supp.2d 946 (N.D. Cal. 2006) (full-text).

Trial Court Proceedings Edit

The district court denied Target's motion to dismiss to the extent it alleged that the inaccessibility of the retailer's website impeded the full and equal enjoyment of goods and services offered in the retailer's stores. The motion to dismiss was granted in part concerning the aspects of the website that offered information and services unconnected to the retailer's store.

The court noted that the purpose of the Americans with Disabilities Act of 1990 (ADA) was "broader than mere physical access" and that "[t]o the extent defendant argues that plaintiffs' claims are not cognizable because they occur away from a 'place' of public accommodation, defendant's argument must fail."

The court required that there be a "nexus" between the Internet services and the physical place in order to present an actionable ADA claim.

The case was settled on August 27, 2008.

External link Edit

  • Isabel Arana DuPree, "Websites as 'Places of Public Accommodation': Amending the Americans with Disabilities Act in the Wake of National Federal of the Blind v. Target Corporation," North Carolina J.L. & Tech. 273 (2007)
  • Jeffrey Bashaw, "Applying the Americans with Disabilities Act to Private Websites after National Federation of the Blind v. Target," 4 Shidler J.L. Com. & Tech. 3 (2008).

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