14.  Thom Browne owns and operates stores throughout the United States,  including a location at 100 Hudson Street, New York, New York. It sells, at these stores,  shirts, pants, jackets, eyewear, shoes, accessories and similar items.   15.  Thom Browne’s Website is heavily integrated with its stores, serving as a  gateway to them. Through the Website, Thom Browne’s customers are, inter alia, able  to: learn information about the stores’ locations and hours of operation; the items for sale  in the stores and online, including available sizes, the materials used, details about the  items, and care instructions; purchase items for delivery; learn about the return policy;  learn about the “New Arrivals” and “Collections”; learn about the company; learn about  items on sale; and read and view the “TB Journal.”   17.  Plaintiff Olsen cannot use a computer without the assistance of screen- reading software. He is, however, a proficient screen-reader user and uses it to access the  Internet. He has visited the Website on separate occasions using screen-reading software.   20.  Due to the inaccessibility of its Website, blind and visually-impaired  customers such as Plaintiff Olsen, who need screen-readers, cannot fully and equally use  or enjoy the facilities, goods, and services Thom Browne offers to the public on its  Website. The Website’s access barriers that Plaintiff Olsen encountered have caused a  denial of his full and equal access in the past, and now deter him on a regular basis from  accessing the Website. These access barriers have likewise deterred him from visiting  Thom Browne’s stores and enjoying them equal to sighted individuals.    21.  If the Website was equally accessible to all, Plaintiff Olsen could  independently navigate it, view goods and service items, locate Thom Browne’s stores  and learn their hours of operation, learn about the items for sale and complete a desired  transaction as sighted individuals do.   22.  Through his attempts to use the Website, Plaintiff Olsen has actual  knowledge of the access barriers that make these services inaccessible and independently  unusable by blind and visually-impaired people.    24.  Thom Browne therefore uses standards, criteria or methods of  administration that have the effect of discriminating or perpetuating the discrimination of  others, as alleged herein.   25.  Title III of the ADA expressly contemplates the injunctive relief that  Plaintiff Olsen seeks under 42 U.S.C. § 12188(a)(2).   27.  Although Thom Browne may currently have centralized policies on  maintaining and operating its Website, Thom Browne lacks a plan and policy reasonably  calculated to make them fully and equally accessible to, and independently usable by,  blind and other visually impaired consumers.   28.  Without injunctive relief, Plaintiff Olsen and other visually impaired  consumers will continue to be unable to independently use the Website, violating its  rights.   29.  Thom Browne has, upon information and belief, invested substantial sums  in developing and maintaining its Website and has generated significant revenue from the  Website. These amounts are far greater than the associated cost of making its Website  equally accessible to visually impaired customers.   31.  Plaintiff Olsen seeks to certify a nationwide class under Fed. R. Civ. P.  23(a) and 23(b)(2): all legally blind individuals in the United States who have attempted  to access Thom Browne’s Website and as a result have been denied access to the equal  enjoyment of goods and services offered in Thom Browne’s stores during the relevant  statutory period (“Class Members”).   32.  Plaintiff Olsen seeks to certify a State of New York subclass under Fed. R.  Civ. P. 23(a) and 23(b)(2): all legally blind individuals in the State of New York who  have attempted to access the Website and as a result have been denied access to the equal  enjoyment of goods and services offered in Thom Browne’s stores during the relevant  statutory period (“New York Subclass Members”).   33.  Plaintiff Olsen seeks to certify a New York City subclass under Fed. R.  Civ. P. 23(a) and 23(b)(2): all legally blind individuals in the New York City who have  attempted to access the Website and as a result have been denied access to the equal  enjoyment of goods and services offered in Thom Browne’s stores during the relevant  statutory period (“New York City Subclass Members”).   35.  Plaintiff Olsen’s claims are typical of the Class Members, New York  Subclass Members and New York City Subclass Members: they are all severely visually  impaired or otherwise blind, and claim that Thom Browne has violated Title III of the  ADA, NYSHRL or NYCHRL by failing to update or remove access barriers on its  Website so it can be independently accessible to the visually impaired individuals.   36.  Plaintiff Olsen will fairly and adequately represent and protect the Class  and Subclasses’ interests because he has retained and is represented by counsel  competent and experienced in complex class action litigation, and because he has no  interests antagonistic to the Class or Subclasses. Class certification of the claims is  appropriate under Fed. R. Civ. P. 23(b)(2) because Thom Browne has acted or refused to  act on grounds generally applicable to the Class and Subclasses, making appropriate both  declaratory and injunctive relief with respect to Plaintiff, the Class and Subclasses.   38.  Judicial economy will be served by maintaining this lawsuit as a class  action in that it is likely to avoid the burden that would be otherwise placed upon the  judicial system by the filing of numerous similar suits by people with visual disabilities  throughout the United States.   39.   Plaintiff Olsen, individually and on behalf of the Class Members, repeats  and realleges every allegation of the preceding paragraphs as if fully set forth herein.   40.  Title III of the ADA prohibits “discriminat[ion] 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).   41.  Thom Browne’s stores are public accommodations under Title III of the  ADA, 42 U.S.C. § 12181(7). Its Website is a service, privilege, or advantage of Thom  Browne’s stores. The Website is a service that is integrated with these locations.   42.  Under Title III of the ADA, it is unlawful discrimination to deny  individuals with disabilities the opportunity to participate in or benefit from the goods,  services, facilities, privileges, advantages, or accommodations of an entity. 42 U.S.C. §  12182(b)(1)(A)(i).   44.  Under Title III of the ADA, unlawful discrimination also includes, among  other things:  [A] failure to make reasonable modifications in policies, practices, or  procedures, when such modifications are necessary to afford such goods,  services, facilities, privileges, advantages, or accommodations to  individuals with disabilities, unless the entity can demonstrate that making  such modifications would fundamentally alter the nature of such goods,  services, facilities, privileges, advantages or accommodations; and a  failure to take such steps as may be necessary to ensure that no individual  with a disability is excluded, denied services, segregated or otherwise  treated differently than other individuals because of the absence of  auxiliary aids and services, unless the entity can demonstrate that taking  such steps would fundamentally alter the nature of the good, service,  facility, privilege, advantage, or accommodation being offered or would  result in an undue burden.  42 U.S.C. § 12182(b)(2)(A)(ii)-(iii).   45.  These acts violate Title III of the ADA, and the regulations promulgated  thereunder. Plaintiff Olsen, who is a member of a protected class of persons under Title  III of the ADA, has a physical disability that substantially limits the major life activity of  sight under 42 U.S.C. §§ 12102(1)(A)-(2)(A). Furthermore, he has been denied full and  equal access to the Website, has not been provided services that are provided to other  patrons who are not disabled, and has been provided services that are inferior to the  services provided to non-disabled persons.    47.  Plaintiff Olsen, individually and on behalf of the New York Subclass  Members, repeats and realleges every allegation of the preceding paragraphs as if fully  set forth herein.   48.  Thom Browne’s State of New York store constitutes a sales establishment  and public accommodation under N.Y. Exec. Law § 292(9). Thom Browne’s Website is a  service, privilege or advantage of Thom Browne. Thom Browne’s Website is a service  that is by and integrated with that store.   49.  Thom Browne is subject to NYSHRL because it owns and operates its  New York store and the Website. Thom Browne is a “person” under N.Y. Exec. Law §  292(1).   50.  Thom Browne is violating the NYSHRL in refusing to update or remove  access barriers to its Website, causing its Website and the services integrated with its  stores to be completely inaccessible to the blind. This inaccessibility denies blind patrons  full and equal access to the facilities, goods and services that Thom Browne makes  available to the non-disabled public. N.Y. Exec. Law §§ 296(2)(a), 296(2)(c)(i),  296(2)(c)(ii).   52.  Thom Browne’s actions constitute willful intentional discrimination  against the class because of a disability, violating the NYSHRL, N.Y. Exec. Law §  296(2), in that Thom Browne has:  a.  Constructed and maintained a website that is inaccessible to Class  Members with knowledge of the discrimination; and/or  b.  Constructed and maintained a website that is sufficiently intuitive  and/or obvious that is inaccessible to blind class members; and/or  c.  Failed to take actions to correct these access barriers in the face of  substantial harm and discrimination to blind class members.   53.  Thom Browne discriminates, and will continue in the future to  discriminate against Plaintiff Olsen and New York Subclass Members on the basis of  disability in the full and equal enjoyment of the goods, services, facilities, privileges,  advantages, accommodations and/or opportunities of Thom Browne’s Website and its  stores under § 296(2) et seq. and/or its implementing regulations. Unless the Court  enjoins Thom Browne from continuing to engage in these unlawful practices, Plaintiff  and the New York Subclass Members will continue to suffer irreparable harm.   55.  Plaintiff Olsen, individually and on behalf the New York City Subclass  Members, repeats and realleges every allegation of the preceding paragraphs as if fully  set forth herein.   56.  Thom Browne’s New York City location is a sales establishment and  public accommodation under the NYCHRL, N.Y.C. Admin. Code § 8-102(9), and its  Website is a service that is integrated with its establishment.   57.  Thom Browne is subject to NYCHRL because it owns and operates its  store in the New York City and its Website, making it a person under N.Y.C. Admin.  Code § 8-102(1).   58.  Thom Browne is violating the NYCHRL in refusing to update or remove  access barriers to Website, causing its Website and the services integrated with its stores  to be completely inaccessible to the blind. This inaccessibility denies blind patrons full  and equal access to the facilities, goods, and services that Thom Browne makes available  to the non-disabled public. N.Y.C. Admin. Code §§ 8-107(4)(a), 8-107(15)(a).   60.  As such, Thom Browne discriminates, and will continue in the future to  discriminate against Plaintiff Olsen and the New York City Subclass Members because of  disability in the full and equal enjoyment of the goods, services, facilities, privileges,  advantages, accommodations and/or opportunities of its Website and its establishment  under § 8-107(4)(a) and/or its implementing regulations. Unless the Court enjoins Thom  Browne from continuing to engage in these unlawful practices, Plaintiff and the New  York City Subclass will continue to suffer irreparable harm.   61.  As Thom Browne’s actions violate the NYCHRL, Plaintiff Olsen seeks  injunctive relief to remedy the discrimination, compensatory damages, civil penalties and  fines for each offense, and attorneys’ fees and expenses. N.Y.C. Admin. Code §§ 8-120,  8-126(a).  62.  Plaintiff Olsen, individually and on behalf the Class Members, repeats and  realleges every allegation of the preceding paragraphs as if fully set forth herein.   64.  A judicial declaration is necessary and appropriate now in order that each  of the parties may know its respective rights and duties and act accordingly.  DECLARATORY RELIEF   Thom Browne, Its Website And Its Website’s Barriers   VIOLATIONS OF THE ADA, 42 U.S.C. § 12181 et seq.   VIOLATIONS OF THE NYCHRL   VIOLATIONS OF THE NYSHRL  