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Law Office of R. Stephen Hall, LLC – R. STEPHEN HALL – ADA Website and FFHA Lawsuits and Claims

The Karlin Law Firm LLP defends these claims and also works with businesses, website owners, web developers and webmasters to bring websites into compliance in a way that will avoid ADA violation claims. Web developers will often focus on WCAG 2.0 or WCAG 2.1, but much more needs to be addressed, and knowledge and experience in the current state of the law are critical to protect businesses, which needs to be explained to the web developer working on a website. The Karlin Law Firm LLP has resolved over 1,600 ADA cases, half of which are now website claims and cases. We both defend and provide the needed guidance in website compliance.

As of recently, Attorney R. Stephen Hall has been targeting websites and representing the plaintiff, Pursuit of Respect, Inc. to make website claims regarding inaccessibility. Below is an example of the letter that is sent out by R. Stephen Hall.

Law Office of R. Stephen Hall, LLC
7322 E. 7th Avenue, Unit 1
Denver, Colorado 80230
(303) 502-4904
[email protected]


Via U.S. Mail and Email

Company Name
123 Main St.
City, State, Zip code
Email address

Dear Mr. (NAME):

This letter constitutes a formal demand, on behalf of my client, Pursuit of Respect, Inc. (hereinafter “Client”), a not-for-profit organization based in Washington, DC, advocating for persons with disabilities who live throughout the nation, for violation of the Federal Fair Housing Act of 1988, Title VIII, 42 U.S.C. § 3601 et seq., (hereinafter “FFHA”), State equivalent statutes, and Section 302(b)(1) of Title III of the American with Disabilities Act (ADA). This demand specifically regards inaccessibility to the visually impaired to your company’s website (hereinafter “Website”) and requests rectification of same as detailed below.

My Client, which is committed to, inter alia, equal access, equal opportunity, and equal rights for protected classes, seeks compliance with the FFHA, ADA, and Fair Housing provisions of the Colorado Civil Rights Act, which make it unlawful to deny individuals with disabilities an opportunity to participate in or benefit from the goods, services, facilities, privileges, advantages, or accommodations, which are afforded to other individuals. Furthermore, it hopes to educate persons and businesses on how to remedy these violations and, when necessary and appropriate, file litigation to require those in violation of these laws to comply with them.

While attempting to access your company’s Website at (URL), using American Foundation for the Blind (AFB) approved screen-reading software, and utilizing Web Content Accessibility Guidelines (hereinafter “WCAG”), our Client’s Tester, who is visually impaired, encountered several access barriers, denying full and equal access to information and/or services related to FFHA and Fair Housing provisions of the Colorado Civil Rights Act covered services offered and made available to the public on your Website.

Some of the substantial errors and challenges encountered on the Website are described in a User Way Report prepared by my Client, a portion of which containing a couple of examples is attached hereto. The barriers encountered by my Client’s Tester demonstrate a discriminatory impact on those who are visually impaired, in violation of, among other things, the FFHA and the Colorado Civil Rights Act. This discriminatory impact is the direct result of your Website’s non-compliance with the above standards; specifically, the Website violates Federal and Colorado state law by publishing services related to housing on your Website without reasonable accommodations for blind and visually impaired persons.

The Federal Fair Housing Act, 42 U.S.C.S. § 3604(c), specifically states, in part:

“…it shall be unlawful:

(c) To make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination.”

Similarly, the Fair Housing provision of the Colorado Civil Rights Act, C.R.S. § 24-34-502(1)(d) provides, in part:

“(1) It shall be an unfair housing practice and unlawful and hereby prohibited: (d) For any person to make, print, or publish or cause to be made, printed, or published any notice of advertisement relating to the sale, transfer, rental, or lease of any housing that indicates any preference, limitation, specification, or discrimination based on disability, race, creed, color, religion, sex, sexual orientation, marital status, familial status, national origin, or ancestry.”

Your Website’s violation of these provisions presents unique challenges to members of the blind and visually disabled community in that the violations deprive them of important social, professional, and economic benefits that arise from the enjoyment of non-discriminatory housing-related practices and services.

These provisions were intended to be enforced by private rights of action and subject you where appropriate to damages, civil penalties, injunctive relief, and attorney fees and costs. See C.R.S. §§ 24-34-505.6 & 508. To that end, my Client hired this firm. On behalf of my Client, we hereby demand that you undertake to make your Website readily accessible to and usable by blind and visually impaired individuals. As a direct and proximate result of your Website’s noncompliance with fair housing regulations, my Client necessarily incurred costs and attorney fees related to its compliance and enforcement efforts. These include, but are not limited to, research into your company’s discriminatory housing-related Website non-compliance status, its diversion of organizational resources, and work performed on behalf of my Client by this firm. The above statutes grant attorney fees and costs to a claimant such as my Client.

Should you choose to resolve this matter without litigation by agreeing to make your Website WCGA compliant, and executing a Settlement Agreement, your company will receive the following:

1. A conditional release from my client, in exchange for your remedying the issues discovered on your Website within an agreed-upon reasonable period of time;
2. A conditional release from my firm, in exchange for reasonable attorney fees and costs; and

3. A WCAG 2.0 & FFHA Website Compliance Assessment of your Website.

Whether you achieve compliance through pre-suit resolution, remediation, and settlement, or other remedies available at law is, of course, completely your choice; please let me know within ten (10) business days of this correspondence. Should you fail to respond to this demand letter and reach a resolution, we reserve the right to seek judicial enforcement through private litigation, in addition to any remedies that maybe available through the Colorado Civil Rights Division, Department of Justice, or Secretary of Housing and Urban Development, without further notice.

Very truly yours,

/s/R. Stephen Hall
R. Stephen Hall
Law Office of R. Stephen Hall, LLC