23.  Defendant offers the https://www.lazybearsf.com/ 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’s website, include but are not limited to the following: ordering online for pickup; the  camp commissary menu which allows consumers to order takeout food a la carte or dinner kit  pickups such as the take-and-bake cookie dough, aged cheddar fondue, radicchio and marinated  Romanesco salad, brown steakhouse bread, roasted hen of the woods mushrooms, wagyu  striploin, and honeynut squash cheesecake; tickets, which serve the function of reservations;  dinner tickets; private events such as off-site events outdoors or at a private residence, cooking  classes, cocktail and spirits classes, and wine tastings; wine list containing over 1,500 selections;  Defendant’s story; contact information; career opportunities; and gift cards.  Consumers can  further access information regarding the restaurant location and hours, social media web pages,  joining Defendant’s email list, and Covid-19 policies.   42.  Plaintiff, on behalf of himself 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.   43.  The California Class is initially defined as follows:  all legally blind individuals in the State of California 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.   44.  Excluded from each of the above Classes is Defendant, including any entity in  which Defendant has a controlling interest, is a parent or subsidiary, or which is controlled by  Defendant, as well as the officers, directors, affiliates, legal representatives, heirs, predecessors,  successors, and assigns of Defendant.  Also excluded are the judge and court personnel in this  case and any members of their immediate families.  Plaintiff reserves the right to amend the Class  definitions if discovery and further investigation reveal that the Classes should be expanded or  otherwise modified.   55.  Plaintiff alleges and incorporates herein by reference each and every allegation  contained in paragraphs 1 through 54, inclusive, of this Complaint as if set forth fully herein.   56.  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).    61.  Plaintiff alleges and incorporates herein by reference each and every allegation  contained in paragraphs 1 through 60, inclusive, of this Complaint as if set forth fully herein.   62.  Defendant’s restaurant 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 goods and services in California through its restaurant and related services, and  https://www.lazybearsf.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.lazybearsf.com/.  These violations are ongoing.   63.  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.   64.  Defendant is also violating the Unruh Civil Rights Act, California Civil Code § 51  et seq. in that the conduct alleged herein likewise constitutes a violation of various provisions of  the ADA, 42 U.S.C. § 12101 et seq. Section 51(f) of the California Civil Code provides that a  violation of the right of any individual under the ADA shall also constitute a violation of the  Unruh Civil Rights Act.   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)  