22.  Defendant offers the https://www.eddiebauer.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  locations. The goods and services offered by Defendant include, but are not limited  to the following, which allow consumers to: find information about store locations,  clearance items, rewards, offers, shipping and returns; access to an assortment of  men and women’s ready to wear apparel and outerwear including parkas, jackets,  pants, jeans, tights, capris, shorts, skirts, t-shirts, tank tops, sweaters, sweatshirts,  hoodies, dresses; accessories including belts, gloves, hats, scarves, sunglasses,  socks; footwear including boots, sneakers, hiking, casual slip-ons, sandals, slippers;  recreation and travel gear including backpacks, duffels, luggage, laptop bags, tents,  sleeping bags, lighting, canteens, flasks, bottles, tote bags; houseware including  down comforters, throws, sheets, pillows, mattress pads, duvet covers, shams and  other products and services that are available for purchase online and in store  locations.    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 with 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 variety of footwear, apparel and  accessories offered to the public through Defendant’s Website.   Defendant’s Barriers on Unruh Civil Rights Act. Cal. Civ. Code, § 51(f) Deny  Plaintiff and Class Members’ Access   41. 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) (b)(3), 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 53, 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 53, inclusive, of this Complaint as if  set forth fully herein.   61.  Defendant’s locations are “business establishments” 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  locations and related services and https://www.eddiebauer.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.eddiebauer.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 Unruh Civil Rights Act, California Civil Code § 51 et seq.  (On Behalf of Plaintiff and the California Class)   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)  