18. Plaintiff was born with a permanent physical disability, specifically spastic  quadriplegic cerebral palsy, and must daily rely on her use of a wheelchair  and ankle foot orthotics.   19. Plaintiff also has visual impairment and is in need of assistance in her daily  life.   20. Plaintiff frequently participates in various marathons by riding a customized  racing wheelchair with an assistance of her mother as a “pusher,” Kelli  King-Tanghe, a non-disabled person, in a so called “duo team.”   21. Plaintiff, together with her mother, participated in over 60 races as a “duo  team,” sharing the joy of participation and competition with other non- disabled race applicants.   22. Duo teams are generally permitted to participate in marathons, where one  non-disabled individual is pushing the wheelchair with the permanently  disabled individual.   23. Defendant is sponsoring and organizing 2017 Chicago Marathon event,  which is scheduled to take place on October 8, 2017.   24. Defendant’s 2017 Chicago Marathon is open to all willing participants,  including duo teams.   25. The lottery drawing for the duo teams took place on January 24, 2017.    26. The duo teams are the only disabled athletes that are required to participate  in a lottery drawing to determine participation for the Chicago Marathon.  44. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (the “Class”).   45. Plaintiff represents, and is a member of the Class, consisting of:  All permanently disabled persons within the United  States who require an assistance of a “pusher” and have  timely applied to participate at the Defendant’s 2017  Chicago Marathon event.    46. Defendant and its employees or agents are excluded from the Class.   Plaintiff does not know the number of members in the Class, but believes the  Class members number in the several hundreds, if not more.  Thus, this  matter should be certified as a Class action to assist in the expeditious  litigation of this matter.   47. Plaintiff and members of the Class were harmed by the acts of Defendant in  at least the following ways: Defendant, either directly or through their  agents, illegally discriminated against Plaintiff and the Class members on the  grounds of Plaintiff’s and Class members’ permanent disability in that  Plaintiff and Class members require an assistance of a “pusher” to  participate in 2017 Chicago Marathon event.  Plaintiff and the Class  members were denied of full and equal opportunity to participate in the  Chicago Marathon event.  TITLE III OF THE ADA  42 U.S.C. § 12181 ET SEQ         • Injunctive relief prohibiting such conduct in the future;  • Injunctive relief requiring Defendant to conduct a separate drawing for  Plaintiff and Class members to remedy the discrimination and provide  them with an equal opportunity to participate in a separate non- discriminatory lottery in order for 2017 Chicago Marathon event;  • Litigation costs;  • Attorneys’ fees;  • Any other relief the Court may deem just and proper. 