55.  Despite these risks, Plaintiff Badger plans to return to Defendants’ facilities, as she  travels frequently throughout the Pittsburgh region visiting friends and family for shopping and  dining, including to the Subject Properties.   Furthermore, Plaintiff Badger intends to return to  Defendants’ facilities to ascertain whether those facilities remain in violation of the ADA.   56.  Plaintiff Gellatly plans to return to Defendants’ facilities, as she attends university  in Western Pennsylvania and regularly travels throughout the area visiting friends and family for  shopping and dining, including to the Subject Properties.  Furthermore, Plaintiff Gellatly intends  to return to Defendants’ facilities to ascertain whether those facilities remain in violation of the  69.  Plaintiffs bring this class action, pursuant to Rules 23(a) and 23(b)(2) of the Federal  Rules of Civil Procedure, on behalf of themselves and the following nationwide class:  all  wheelchair users who have attempted, or will attempt, to utilize the parking facilities at all  locations within the United States for which Defendants own and/or control the parking facilities.   71.  Typicality:  Plaintiffs’ claims are typical of the claims of the members of the class.   The claims of Plaintiffs and members of the class are based on the same legal theories and arise  from the same unlawful conduct.   72.  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, Defendants’ facilities and/or services due to Defendants’ failure to make their facilities fully  accessible and independently usable as above described.   73.  Adequacy of Representation:  Plaintiffs are an adequate representative of the class  because their interests do not conflict with the interests of the members of the class.  Plaintiffs will  fairly, adequately, and vigorously represent and protect the interests of the members of the class  and have no interests antagonistic to the members of the class.  Plaintiffs have retained counsel  who are competent and experienced in the prosecution of class action litigation, generally, and  who possess specific expertise in the context of class litigation under the ADA.   74.  Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because  Defendants have acted or refused to act on grounds generally applicable to the Class, making  appropriate both declaratory and injunctive relief with respect to Plaintiffs and the Class as a  whole.    I.  Plaintiffs Have Been Denied Full and Equal Access to Defendants’ Facilities.  