14.    Defendant owns, manages and/or operates the Hotel.    15.   As part of its operations, Defendant provides its customers and the public  reservations services, including, but not limited to, the ability to reserve rooms online via  the Website.    16.   Within the applicable limitations period, Plaintiff visited the Website to identify the  accessible features of the Hotel and its guest rooms to determine whether it met her  accessibility needs.     17.   Plaintiff was unable to independently ascertain the accessible features of the Hotel  and its guest rooms by reference to the Website as required by the ADA.  42 U.S.C. §  12182 et seq. and 28 C.F.R. § 36.302(e)(1) et seq. (“ADA Accessibility Standards”).   18.   An investigation performed on Plaintiff’s behalf confirmed the allegations made by  Plaintiff in paragraphs 16 through 17.   19.   The barriers to access on the Website, all encountered by Plaintiff, include but are  not limited to, the following:   a)  The Website fails to disclose the physical barriers to access identified in the  preceding section.  These physical access barriers represent material  elements of the Hotel that do not comply with applicable ADA Standards.   Defendant’s failure to identify them prevents Plaintiff and other individuals  with disabilities from independently determining if the Hotel meets his or  her accessibility needs.  5  b)  On the homepage of www.redlion.com/americas-best-value-inn/oh/brook- park/americas-best-value-inn-cleveland-airport, there is a general  description of the Hotel's location and features; however, none of the  information provided relates to accessibility as required by ADA  accessibility standards.  c)  There is a link labeled “Contact” which provides information on how to  contact the Hotel; however, none of the information provided relates to  accessibility as required by ADA accessibility standards.  d)  There is a link labeled “Details” which provides a description and a list of  features the Hotel offers. One of the features is labeled as “Handicap  Accessible”; however, this item lacks specificity and does not provide  sufficient detail for Plaintiff to determine whether the Subject Property will  meet her accessibility needs as required by ADA accessibility standards.  e)  There is a link labeled “Hotel Amenities” which lists the various amenities  the Hotel offers. One of the amenities is “Accessibility Features.” However,  because no accessibility features are identified, the information lacks  specificity and is insufficient for Plaintiff to determine if it meets her  accessibility needs as required by ADA accessibility standards.  f)        On information and belief, amenities or features designated as accessible by  Defendant are not included in the inventory of amenities searchable via the  Website and it’s reservation systems in violations of ADA accessibility  standards.  6  g)  There is a link labeled “Room Types” which offers photos, a description,  and a “Select This Room” link for each of the Hotel's three room options;  however, none of the information provided relates to accessibility as  required by ADA accessibility standards.  h)   Remaining links from the homepage do not contain information regarding  accessibility as required by ADA accessibility standards.  i)   When attempting to make a reservation, Plaintiff was unable to book a room  because she was unable to find any information or room option pertaining  to accessibility as required by ADA accessibility standards.   20.   Defendant’s failure to modify its policies, practices and procedures to ensure that  individuals with disabilities can make reservations for accessible guest rooms during the  same hours and in the same manner as individuals who do not need accessible rooms is  discriminatory and violates ADA Accessibility Standards.   21.   Plaintiff is a tester in this litigation and a consumer who wishes to access  Defendant’s good and services at the Hotel.  Plaintiff is being deterred from patronizing  the Hotel on particular occasions but intends to return to the Hotel and the Website for the  dual purpose of availing herself of the goods and services offered to the public by the Hotel  and to ensure that Defendant ceases evading its responsibilities under federal law.   22.   However, the lack of accessible reservations services has deterred Plaintiff from  staying at the Hotel.   23.   Plaintiff has been, and in the absence of an injunction will continue to be, injured  by Defendant’s policy and practice of failing to provide accessible reservations services to  persons with disabilities.   7  24.   Plaintiff brings this action under Rule 23(a) and (b)(2) of the federal rules of civil  procedure and on behalf of herself and the following class: “All individuals with disabilities  who have been, or in the future will be, denied the full and equal enjoyment of reservations  services offered to guests at the Hotel because of the lack of accessible reservations services  through the Website.”   25.   Numerosity: The class described above is so numerous that joinder of all individual  members in one action would be impracticable. The disposition of the individual claims of  the respective class members through this class action will benefit both the parties and the  Court and will facilitate judicial economy.   26.   Typicality:  Plaintiff’s claims are typical of the claims of the members of the class.  The claims of Plaintiff and members of the class are based on the same legal theories and  arise from the same unlawful conduct.   27.   Common Questions of Fact and Law:  There is a well-defined community of  interest and common questions of fact and law affecting members of the class 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, Defendant’s goods, services and facilities due to the policies and  practices described above.   28.   Adequacy of Representation:  Plaintiff is an adequate representative of the class  because her interests do not conflict with the interests of the members of the class. Plaintiff  will fairly, adequately, and vigorously represent and protect the interests of the members  of the class and has no interests antagonistic to the members of the class. Plaintiff has  retained counsel who are competent and experienced in the prosecution of class action  8  litigation, generally, and who possess specific expertise in the context of litigation under  the ADA.   29.   Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because  Defendant has acted or refused to act on grounds generally applicable to the class, making  appropriate both declaratory and injunctive relief with respect to Plaintiff and the class as  a whole.  30.   Plaintiff incorporates by reference the allegations stated in paragraphs “1” through  “23” of this complaint as if fully stated herein.    31.   Plaintiff brings this claim individually and on behalf of the class.   32.   Plaintiff is an individual with a disability under the ADA. 42 U.S.C. § 12102(1)(A).   33.   Defendant, a hospitality business, is public accommodation under the ADA. 42  Violations of 42 U.S.C. §§ 12181, et seq.  