15.  Defendant manages and/or operates many hotels throughout the United States.     16.  As part of these operations, Defendant provides its customers transportation  services, including, but not limited to, complimentary shuttle services.   17.  Within the applicable limitations period, Plaintiff called the Holiday Inn and was  told by an agent of Defendant that the Holiday Inn provides a complimentary shuttle service for  guests.   18.  Plaintiff was told that the complimentary shuttle service was not wheelchair  accessible and was told that Defendant would not provide an alternative transportation service.   19.  An investigation performed on Plaintiff’s behalf confirmed the allegations made by  Plaintiff above.     20.  The investigation performed on behalf of Plaintiff further confirmed that, in  addition to the Holiday Inn, Defendant manages and/or operates a substantial number of other hotels  in the United States that offer transportation services to their guests, but do not offer equivalent  transportation services to guests who use wheelchairs or scooters.   23.  Plaintiff brings this action under Rule 23(a) and (b)(2) of the federal rules of civil  procedure and on behalf of herself and the following class: “All individuals who use wheelchairs  or scooters for mobility and who have been, or in the future will be, denied the full and equal  enjoyment of transportation services offered to guests at hotels owned and/or operated by  Defendant because of the lack of equivalent accessible transportation services at those hotels.”   24.  Numerosity: The class described above is so numerous that joinder of all individual  members in one action would be impracticable.  The disposition of the individual claims of the  respective class members through this class action will benefit both the parties and the Court, and  will facilitate judicial economy.     25.  Typicality:  Plaintiff’s claims are typical of the claims of the members of the class.   The claims of Plaintiff and members of the class are based on the same legal theories and arise  from the same unlawful conduct.   27.  Adequacy of Representation:  Plaintiff is an adequate representative of the class  because her interests do not conflict with the interests of the members of the class.  Plaintiff will  fairly, adequately, and vigorously represent and protect the interests of the members of the class  and has no interests antagonistic to the members of the class.  Plaintiff has retained counsel who  are competent and experienced in the prosecution of class action litigation, generally, and who  possess specific expertise in the context of class litigation under the ADA.   28.  Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because  Defendant has acted or refused to act on grounds generally applicable to the class, making  appropriate both declaratory and injunctive relief with respect to Plaintiff and the class as a whole.  29.  Plaintiff incorporates by reference each and every allegation herein.   30.  Plaintiff brings this claim individually and on behalf of the class.   31.  Plaintiff is an individual with a disability under the ADA.  42 U.S.C. § 12102(1)(A).   32.  Defendant, a hospitality business, is public accommodation under the ADA.  42  Violations of 42 U.S.C. §§ 12181, et seq.  