22.  Defendant offers the https://www.bailey44.com/ website, Defendant’s  Website, to the public.  The website offers features which should allow all  consumers to access the goods and services which Defendant offers in connection  with its physical location. The goods and services offered by Defendant include,  but are not limited to the following, which allow consumers to access: spa/hot  springs goods and services, including 44-hr Flash Sale, Icons, Jackets, Tops,  Dresses, Bottoms, Sale, Shop All, as well as size chart, returns, shipping, and  contact us, and information about products and services which are available online  and in retail stores for purchase.    23.  Based on information and belief, it is Defendant’s policy and practice  to deny Plaintiff and Class Members, along with other blind or visually impaired  users, access to Defendant’s website, and to therefore, specifically deny the goods  and services that are offered and integrated within Defendant’s stores. Due to  Defendant’s failure and refusal to remove access barriers on its website, Plaintiff  and other visually impaired persons have been and are still being denied equal and  full access to Defendant’s stores and the numerous goods, services, and benefits  offered to the public through Defendant’s Website.   Defendant’s Barriers on https://www.bailey44.com/  Deny Plaintiff and Class Members’ Access   24.  Plaintiff is a visually impaired and legally blind person, who cannot  use a computer without the assistance of screen reading software. However,  Plaintiff is a proficient user of the JAWS screen-reader as well as Mac’s VoiceOver  and  she  uses  both  to  access  the  internet.  Plaintiff  has  visited  https://www.bailey44.com/ on several separate occasions using the JAWS and/or  VoiceOver screen-readers.   41.  Plaintiff, on behalf of herself and all others similarly situated, seeks to  certify a Nationwide Class under Fed. R. Civ. P. 23(a) and 23(b)(2), the Nationwide  Class is initially defined as follows:   all legally blind individuals who have attempted to access Defendant’s  website by the use of a screen reading software during the applicable  limitations period up to and including final judgment in this action.   54.  Plaintiff alleges and incorporates herein by reference each and every  allegation contained in paragraphs 1 through 50, inclusive, of this Complaint as if  set forth fully herein.   55.  Section 302(a) of Title III of the ADA, 42 U.S.C. § 12181 et seq.,  provides: “No individual shall be discriminated against on the basis of disability in  the full and equal enjoyment of the goods, services, facilities, privileges,  advantages, or accommodations of any place of public accommodation by any  person who owns, leases (or leases to), or operates a place of public  accommodation.” 42 U.S.C. § 12182(a).    60.  Plaintiff alleges and incorporates herein by reference each and every  allegation contained in paragraphs 1 through 50, inclusive, of this Complaint as if  set forth fully herein.   61.  Defendant’s location is a “business establishment” within the meaning  of the California Civil Code § 51 et seq.  Defendant generates millions of dollars in  revenue from the sale of its services in California through its store’s location and  related services and https://www.bailey44.com/ is a service provided by Defendant  that is inaccessible to customers who are visually impaired like Plaintiff and Class  Members. This inaccessibility denies visually impaired customers full and equal  access to Defendant’s facilities and services that Defendant makes available to the  non-disabled public. Defendant is violating the Unruh Civil Rights Act, California  Civil Code § 51 et seq., in that Defendant is denying visually impaired customers  the services provided by https://www.bailey44.com/. These violations are ongoing.   62.  Defendant’s actions constitute intentional discrimination against  Plaintiff and Class Members on the basis of a disability in violation of the Unruh  Civil Rights Act, Cal. Civil Code § 51 et seq. in that: Defendant has constructed a  website that is inaccessible to Plaintiff and Class Members; maintains the website  in this inaccessible form; and has failed to take adequate actions to correct these  barriers even after being notified of the discrimination that such barriers cause.   Violations of the Americans With Disabilities Act, 42 U.S.C. § 12181 et seq.  (On Behalf of Plaintiff, the Nationwide Class and the California Class)   Violations of the Unruh Civil Rights Act, California Civil Code § 51 et seq.  (On Behalf of Plaintiff and the California Class)  