10. Plaintiff brings this class action on his own behalf, and as a class action, pursuant to Federal  Rule of Civil Procedure 23, on behalf of a class of people defined as follows:   All disabled individuals who have been unable to obtain required  accessibility information online, or to independently secure an  online reservation for an accessible guestroom, by a failure to  comply with the ADA and ADAAG upon any online reservation  platform on which the Hotel is advertised, including the Website.    11. Excluded from the Class is any person who is an executive, officer, employee, and/or  director of the Defendant.    13. Plaintiff’s claims are typical of those of the entire Class.  Plaintiff, along with every  member of the Class, has suffered civil right violations because of Defendant’s continuing  failure to comply with the ADA and ADAAG on its Website and/or other online  reservation platforms.     14.  Plaintiff can and will adequately protect the interests of all members of the Class and has  retained competent counsel experienced in both ADA and class action litigation.  Plaintiff  has no interest that is contrary to the interest of the Class members in this case.   15.  A class action is far superior to any other possible method for adjudicating this  controversy.  Each member of the Class is entitled to injunctive relief, as well as possible  statutory damages under New Jersey law.  The expense and burden associated with  individual litigation of each claim held by each member of the Class would be  extraordinarily inefficient for Defendant, members of the Class, and the courts.    16. Common questions of law and fact prevail with respect to all members of the Class and  predominate over questions applicable solely to individual Class members.  Among such  common questions of law and fact is whether Defendant has violated Federal and New  Jersey State statutory obligations by failing to comply with the ADA, ADAAG, and  NJLAD, such that all physically disabled persons are afforded fair and equal access to any  hotel owned or operated by Defendant, and their online reservation systems.    17.  Plaintiff knows of no special or unique difficulties that would be encountered in the  management of this litigation that might preclude its maintenance as a class action.    19. On July 26, 1990, Congress enacted the ADA, explaining that its purpose was to provide a  clear and comprehensive national mandate for the elimination of discrimination against  individuals with disabilities and to provide clear, strong, consistent, enforceable standards  addressing such discrimination, invoking the sweep of congressional authority in order to  address the major areas of discrimination faced day-to-day by people with disabilities to  ensure that the Federal government plays a central role in enforcing the standards set by  the ADA. 42 U.S.C. § 12101(b)(l) - (4).    20. Pursuant to the mandates of 42 U.S.C. §12134(a), on September 15, 2010, the Department  of Justice, Office of the Attorney General (“DOJ”), published revised regulations for Title  III of the Americans With Disabilities Act of 1990. Public accommodations, including  places of lodging were required to conform to these revised regulations on or before March  15, 2012.   22. In promulgating the new requirements, the Department of Justice made clear that  individuals with disabilities should be able to reserve hotel rooms with the same efficiency,  immediacy, and convenience as those who do not need accessible guestrooms. 28 C.F.R.  Part 36, Appx. A.    24. In addition,   hotel rooms that are in full compliance with current standards may  differ, and individuals with disabilities must be able to ascertain  which features – in new and existing facilities – are included in the  hotel’s accessible guest rooms. For example, under certain  circumstances, an accessible hotel bathroom may meet accessibility  requirements with either a bathtub or a roll in shower. The presence  or absence of particular accessible features such as these may mean  the difference between a room that is usable by a particular person  with a disability and one that is not.   28 C.F.R. Part 36, Appx. A.  Accordingly, Defendant is required to set forth specific  accessible features and not merely recite that a guestroom is “accessible” or “ADA” or list  accessibility features that may (or may not) be offered within a particular room.    25. For hotels in buildings constructed after the effective date of the 1991 Standards, it is  sufficient to advise that the hotel itself is fully ADA compliant, and for each accessible  guestroom, to specify the room type, the type of accessible bathing facility in the room,  and the communications features in the room. 28 C.F.R. Part 36, Appx. A.   27. The Hotel is a place of public accommodation that owns and/or leases and operates a place  of lodging pursuant to the ADA.    28. The Website (and all other online reservation platforms used by the Hotel) allows  reservations for the Hotel to be taken online.  The Defendant has control over information  provided to the public about the Hotel through the Website and/or other online platforms.     29. Prior to filing this lawsuit, Plaintiff visited the Website to learn about accessible features  of the Hotel, and to independently assess whether the Hotel is accessible to him, and  whether he could independently reserve an accessible room at the Hotel, in the same  manner as those seeking to reserve non-accessible rooms.  Upon his respective visit to the  website, Plaintiff discovered that the Website does not comply with the ADA and ADAAG.   32. This is not intended to be an exclusive list, and Plaintiff, on behalf of himself and the class,  brings this action to remediate all violations of the ADAAG found to exist upon the  Website, and upon all online reservation platforms used by the Ho Hotel tel.     33. In addition to the list above, upon information and belief, Defendant may not effectively  (i) ensure that accessible guest rooms are held for use by individuals with disabilities until  all other guest rooms of that type have been rented and the accessible room requested is  the only remaining room of that type; (ii) reserve, upon request, accessible guest rooms or  specific types of guest rooms and ensure that the guest rooms requested are blocked and  removed from all reservations systems; or (iii) guarantee that the specific accessible guest  room reserved through its reservations service is held for the reserving customer, regardless  of whether a specific room is held in response to reservations made by others. Discovery  is required on these issues.    34. Plaintiff will visit the Website again, and members of the Class will visit the Website and  online reservation platforms controlled by Defendant again, upon the Defendant’s  compliance with the laws and regulations specified herein, in order learn about the  accessible (and inaccessible) features, learn about the accessible (and inaccessible) features  of guestrooms, assess the extent to which the hotels meet each of their specific accessibility  needs, and determine whether they can reserve an accessible guestroom.    36. Modifying the Website (and other online reservation platforms, as applicable) to comply  with the ADA and ADAAG is accomplishable without undue burden or expense and is  readily achievable.  But in any event, upon information and belief, the Website has been  altered, updated, and edited, after 2010, but not in a manner compliant with 2010 ADAAG  standards.      37. Defendant will continue to discriminate against Plaintiff and all other disabled individuals  who access the Website (and other online reservation platforms, as applicable) unless and  until Defendant modifies the Website (and other online reservation platforms, as  applicable) to set forth all required information, as set forth above.     38. Plaintiff and the Class are without an adequate remedy at law and are suffering irreparable  harm, and Plaintiff reasonably anticipates that he and the Class will continue to suffer this  harm unless and until Defendant is required to correct the ADA violations found upon the  Websites (and other online reservation platforms, as applicable), and to maintain the  Websites (and other online reservation platforms, as applicable), inclusive of the online  reservation system, and accompanying policies and procedures, in a manner that is  consistent with and compliant with ADA and ADAAG requirements.    40. Plaintiff re-avers the allegations set forth above as though fully set forth herein.    41. The New Jersey Law Against Discrimination provides:   It shall be an unlawful employment practice, or, as the case may be,  an unlawful discrimination: for any owner, lessee, proprietor,  manager, superintendent, agent, or employee of any place of public  accommodation directly or indirectly to refuse, withhold from or  deny to any person any of the accommodations, advantages,  facilities or privileges thereof, or directly or indirectly to publish,  circulate, issue, display, post or mail any written or printed  communication, notice, or advertisement to the effect that any of the  accommodations, advantages, facilities, or privileges of any such  place will be refused, withheld from, or denied to any person on  account of the race, creed , color, national origin, ancestry, marital  status, civil union status, domestic partnership status, pregnancy or  breastfeeding, sex, gender identity or expression, affectional or  sexual orientation, disability . . . 3   42. The Website (and other online reservation platforms, as applicable) is a gateway to, and a  part of, the Hotel, which is a place of public accommodation as defined by the New Jersey  Law Against Discrimination.    43. Plaintiff and the Class have visited the Website (and other online reservation platforms, as  applicable), and encountered barriers made illegal by the ADA and ADAAG, and thus by  the New Jersey Law Against Discrimination.    VIOLATION OF THE AMERICANS WITH DISABILITIES ACT   VIOLATIONS OF THE NEW JERSEY LAW AGAINST DISCRIMINATION  