(Violation of Title III of the Americans with Disabilities Act)  (42 U.S.C. §§ 12101, et seq.)  (Injunctive Relief on Behalf of Plaintiffs and the Class)   24.  Plaintiffs seek certification of the following nationwide class pursuant to  Fed. R. Civ. P. 23(a) and 23(b)(2): “all legally blind individuals who have been and/or are  being denied equal access to the services, privileges, advantages, and accommodations that  Defendants offer through the Greyhound website or mobile software application, because  those services, privileges, advantages, and accommodations are not independently  accessible to blind persons who must use screen-reader software to access websites and  mobile software applications.”   25.  Plaintiffs also seek certification of the following California-wide Subclass  pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3): “all legally blind California individuals who  have been denied equal access to the services, privileges, advantages, and accommodations  that Defendants offer through the Greyhound website or mobile software application,  because those services, privileges, advantages, and accommodations are not independently  accessible to blind persons who must use screen-reader software to access websites and  mobile software applications.”   26.  The persons in the Class and California Subclass are so numerous that  joinder of all such persons is impractical and the disposition of their claims in a class  action is a benefit to the parties and to the Court.   27.  The action involves common questions of law and fact affecting the parties  to be represented in that they all have been and/or are being denied their civil rights to full  and equal access to, and use and enjoyment of, Greyhound’s services, which are made  available through a nexus to the Greyhound website and mobile software application.    36.  Defendants operate a branded Internet website located at  https://www.greyhound.com/ for potential and existing customers to conveniently obtain  information and services related to bus transportation. Among other features on the  website, Greyhound promotes:  •  Browsing bus schedules;  •  Finding bus stops;  •  Booking trips;  •  Exploring travel locations;  •  Managing booked trips;  •  Obtaining general information about Greyhound and its services;  •  Tracking buses in real-time;  •  Managing frequent traveler loyalty accounts;  •  Contacting Greyhound;  •  Getting topical help and answers to frequently asked questions; and  •  Obtaining other useful information and services related to bus travel.   79.  Plaintiffs incorporate by reference the foregoing allegations as though fully  set forth herein.    80.  Members of Plaintiff NFB, including individual Plaintiffs DeWall, Flores,  Hingson, Richardson, and Thomas, are qualified individuals with disabilities within the  meaning of Title III of the ADA. Members of the proposed Class and California Subclass  are qualified individuals with disabilities within the meaning of Title III of the ADA.  Specified Public Transportation   81.  Title III of the ADA prohibits discrimination on the basis of disability in the  full and equal enjoyment of specified public transportation services provided by a private  entity that is primarily engaged in the business of transporting people and whose  operations affect commerce. 42 U.S.C. § 12184(a); 49 C.F.R. § 37.5(a), (f).   82.  Defendants are primarily engaged in the business of transporting people  within the meaning of Title III of the ADA and its regulations. 42 U.S.C. § 12184(a).  Defendants operate specified public transportation within the meaning of Title III of the  ADA and its regulations. 49 C.F.R. §§ 37.3. The operations of Defendants affect  commerce.   Defendants.   Case No. 3:17-cv-3368  CLASS ACTION  The Greyhound.com Website  