23.  Defendant offers the https://www.nine-ten.com/ website to the public.   The website offers features which should allow all consumers to access the goods  and services which Defendant offers in connection with its physical location.  The  goods and services offered by Defendant include but are not limited to the  following: a handpicked wine list, dinner menu, lunch menu, breakfast menu, and  a weekend brunch menu.  Defendant’s website also details the executive chef’s  story and accomplishments; the plethora of awards and accolades received by the  restaurant; positive press coverage; the myriad of rooms and packages available for  special events and private dining experiences, contact information, directions, and  hours of operation.         42.  Plaintiff, on behalf of herself and all others similarly situated, seeks to  certify a Nationwide Class under Fed. R. Civ. P. 23(a) and 23(b)(2), the Nationwide  Class is initially defined as follows:  all legally blind individuals who have attempted to access  Defendant’s website by the use of a screen reading software  during the applicable limitations period up to and including final  judgment in this action.   43.  The California Class is initially defined as follows:  all legally blind individuals in the State of California who have  attempted to access Defendant’s website by the use of a screen  reading software during the applicable limitations period up to  and including final judgment in this action.   44.  Excluded from each of the above Classes is Defendant, including any  entity in which Defendant has a controlling interest, is a parent or subsidiary, or  which is controlled by Defendant, as well as the officers, directors, affiliates, legal  representatives, heirs, predecessors, successors, and assigns of Defendant.  Also  excluded are the judge and court personnel in this case and any members of their  immediate families.  Plaintiff reserves the right to amend the Class definitions if  discovery and further investigation reveal that the Classes should be expanded or  otherwise modified.   55.  Plaintiff alleges and incorporates herein by reference each and every  allegation contained in paragraphs 1 through 54, inclusive, of this Complaint as if  set forth fully herein.   56.  Section 302(a) of Title III of the ADA, 42 U.S.C. § 12181 et seq.,  provides: “No individual shall be discriminated against on the basis of disability in  the full and equal enjoyment of the goods, services, facilities, privileges,  advantages, or accommodations of any place of public accommodation by any  person who owns, leases (or leases to), or operates a place of public  accommodation.” 42 U.S.C. § 12182(a).    61.  Plaintiff alleges and incorporates herein by reference each and every  allegation contained in paragraphs 1 through 60, inclusive, of this Complaint as if  set forth fully herein.   VIOLATIONS OF THE AMERICANS WITH DISABILITIES ACT, 42  U.S.C. § 12181 ET SEQ.  (On Behalf of Plaintiff, the Nationwide Class and the California Class)   VIOLATIONS OF THE UNRUH CIVIL RIGHTS ACT, CALIFORNIA  CIVIL CODE § 51 ET SEQ.   (On Behalf of Plaintiff and the California Class)  