25.  Plaintiff brings this class action on behalf of herself and all others similarly  situated pursuant to Rules 23(a) and 23(b)(2) of the Federal Rules of Civil Procedure, on behalf  of all wheelchair users who have attempted, or will attempt, to access Defendant’s facilities.   26.  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 this Court.   27.  Typicality:  Plaintiff’s claims are typical of the claims of the members of the  class.  The claims of the Plaintiff and members of the class are based on the same legal theories  and arise from the same unlawful conduct.   28.  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 facilities and/or services due to Defendant’s failure to make its  facilities fully accessible and independently usable as above described.   30.  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.    INC.,  Defendant.  Case No.  Filed Electronically 