16.  Defendant  either  owns,  operates  and/or  controls  its  website,  www.planetdodge.com, which offers services related to and heavily integrated with its brick and  mortar show rooms and which offers such services such as viewing vehicle inventory, viewing  specials and accessing coupons, applying for credit, or valuing a trade-in, within South Florida, to  the public.1       18.  The international website standards organization, W3C, has published WCAG   19.  Plaintiff is a prospective customer who is interested in the good and services offered  by Defendant at its brick and mortar locations.     2.0 AA (Version 2.0 of the Web Content Accessibility Guidelines). WCAG 2.0 AA provides  widely accepted guidelines for making websites accessible to individuals with disabilities and  compatible with screen reader software. These guidelines have been endorsed by the United States  Department of Justice and numerous federal courts.    20.  Plaintiff uses screen reader software in order to access a website's content.  However, despite several attempts, Defendant’s website did not integrate with Plaintiff's software,  nor was there any function within the website to permit access for visually impaired individuals  through other means. Plaintiff was denied the full use and enjoyment of the facilities and services  available on Defendant’s website as a result of access barriers on the website in conjunction with  Plaintiff’s use and patronage of Defendant’s brick and mortar campus location in Boca Raton.   21.  Plaintiff also researches locations prior to visiting in person in order to learn  about accessible routes, and accommodations for disabled individuals in advance of an in-person  visit.    22.  Defendant’s website does not meet the WCAG 2.0 AA level of accessibility.   24.  As a result of Defendant’s discrimination, Plaintiff was unable to use Defendant’s  website and suffered an injury in fact including loss of dignity, mental anguish and other tangible  injuries.  Moreover, the digital barriers on Defendant’s website, Plaintiff is denied to participate in  or benefit from the goods, services and accommodations afforded to the public.    25.  The barriers at the website have caused a denial of Plaintiff s full and equal  access multiple times in the past, and now deter Plaintiff from attempting to use Defendant’s  website itself, and in conjunction with visiting its brick and mortar campus location.   26.  If Defendant’s website was accessible, Plaintiff could independently research  the available credit services, trade-in options, vehicle specials, access coupons vehicles in  inventory and schedule appointments.   27.  Although Defendant may have centralized policies regarding the maintenance  and operation of its website, Defendant has never had a plan or policy that is reasonably calculated  to make its website fully accessible to, and independently usable by people with visual  impairments.   28.  Without injunctive relief, Plaintiff and other visually impaired individuals will  continue to be unable to independently use Defendant’s website in violation of their rights under  the ADA.  29.  Plaintiff brings this class action on behalf of himself and all others similarly  situated pursuant to Rules 23(a) and 23(b)(2) of the Federal Rules of Civil Procedure, on behalf  of all legally blind individuals who have attempted, or will attempt, to access Defendant’s website  using screen reader software.   31.  Typicality: Plaintiff’s claims are typical of the claims of the members of the  class. The claims of the Plaintiff and members of the class are based on the same legal theories  and arise from the same unlawful conduct.   32.  Common Questions of Fact and Law:  There is a well-defined community of  interest and common questions of fact and law affecting members of the class in that they all  have been and/or are being denied their civil rights to full and equal access to, and use and  enjoyment of, Defendant’s facilities and/or services due to Defendant’s failure to make its website  fully accessible and independently usable as above described.   33.  Adequacy of Representation: Plaintiff is an adequate representative of the class  because his 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.   34.  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. 