New Players in the ADA Shakedown: Gabriel Levy, Sanjay Gohil & Noor Saab Join the Serial Plaintiff Gold Rush

The ADA website lawsuit machine never sleeps. While you're reading this, somewhere in America, a small business owner is opening an envelope containing their first demand letter. Their crime? Running a website with images that lack alt text, or forms missing proper labels for screen readers. Their punishment? Becoming the latest target in what critics increasingly call a legal shakedown operation that generates millions in settlements while doing little to actually improve web accessibility.

If you've been following the ADA website litigation space, you know the usual suspects – the Gottliebs, the Mizrahi Kroubs, the firms that have turned Title III of the Americans with Disabilities Act into a volume business. But there's a new generation of players entering this lucrative field, and they're following the same playbook with frightening efficiency.

Meet Gabriel Levy, Noor Saab, and Sanjay Gohil – three attorneys who have collectively filed hundreds of cookie-cutter ADA website lawsuits in recent years. Their clients read like characters in a legal drama where everyone plays the same role: the vision-impaired plaintiff who just happens to discover dozens of inaccessible websites every month, each one coincidentally belonging to a business with deep enough pockets to make a lawsuit worthwhile.

The Serial Plaintiff Ecosystem: A Numbers Game

Before we dive into these specific firms, let's understand the ecosystem they're entering. According to industry data from EcomBack, just 11 plaintiff firms filed 91% of all ADA website lawsuits in April 2024. Think about that for a moment – out of hundreds of thousands of lawyers in America, fewer than a dozen firms are responsible for nearly all website accessibility litigation.

The concentration is even more stark when you look at individual plaintiffs. That same April 2024 report shows that a single plaintiff, Jessica Karim, filed 25 lawsuits in one month. That's more than one lawsuit every business day. Either Ms. Karim has an extraordinarily active online shopping habit, or something else is going on here.

The geographic patterns tell their own story. New York federal courts saw 101 of the 232 website ADA lawsuits filed in April 2024 alone. Why New York? Because the state's human rights laws allow for statutory damages on top of federal ADA claims, creating a perfect storm of legal leverage for quick settlements.

This is the world that Levy, Saab, and Gohil have entered – and by all accounts, they're thriving in it.

Gabriel A. Levy, P.C.: The High-Velocity New York Operation

Gabriel Levy runs his practice from New York, and if you're an e-commerce business owner, his name should be on your radar. According to legal tracking sites, Levy's firm has become one of the most active filers of ADA website lawsuits in the Southern and Eastern Districts of New York.

The numbers are staggering. Legal alert services report that Levy's firm had filed roughly 250 ADA lawsuits as of late 2024. But it's not just the volume – it's the velocity. EcomBack's data shows that Levy's firm filed 33 website ADA lawsuits in April 2024 alone, representing over 14% of all such lawsuits filed that month nationwide.

The Levy Plaintiff Network

Behind every serial filing firm is a network of serial plaintiffs, and Levy's roster reads like a who's who of professional ADA testers:

• Jessica Karim – The crown jewel of Levy's plaintiff network. According to lawsuit tracking data, Karim has filed cases against everyone from small boutiques to major retailers like Torrid. Her complaints all follow the same pattern: she's visually impaired, uses screen reader software, visited a website, and couldn't complete a purchase due to accessibility barriers.

• Pedro Liz – Another frequent filer represented by Levy. Public dockets show Liz targeting businesses across industries, from fashion retailers to service companies.

• Alvin Suarez, Alfred Trippett, and Lunique Agostini – Additional plaintiffs in Levy's stable, each with their own collection of federal lawsuits against website operators.

What's remarkable about these cases isn't their variety – it's their uniformity. Pull up any two complaints filed by Levy's firm, and you'll find identical paragraphs with only the defendant's name and website URL changed. The introduction, the jurisdiction claims, the alleged violations – all copied and pasted from a master template.

The Torrid Case: A Template in Action

Let's look at one high-profile example: Karim v. Torrid LLC, a class action against the plus-size fashion retailer. The complaint, like all of Karim's filings, begins with nearly identical language about her visual impairment and reliance on screen reader technology. It then lists the same categories of alleged violations: images without alt text, empty links, redundant links, and inaccessible forms.

The fascinating part? If you check the filing dates, Karim somehow managed to thoroughly test dozens of different websites in the span of a few weeks, each time discovering similar violations that just happened to meet the threshold for federal litigation. Either she has an army of assistants helping her shop online, or these lawsuits are being generated through a more systematic process.

TestParty, an accessibility compliance platform, has analyzed hundreds of these complaints and found that the alleged violations often could have been fixed with basic automated scanning and remediation – the kind of preventive maintenance that costs a fraction of a legal settlement. But that's exactly the point: these lawsuits aren't really about improving accessibility. They're about leveraging the threat of litigation to extract quick settlements from businesses that can't afford to fight back.

The Law Office of Noor A. Saab: From Hundreds of Filings to Consent Decrees

If Gabriel Levy represents the new wave of high-velocity ADA filers, Noor Saab represents something even more concerning: industrial-scale litigation with a veneer of legitimacy through consent decrees.

Operating from Great Neck, New York, Saab's firm appears on every major list of ADA website plaintiff firms. But the real story is in the numbers. Court records show that over just a two-year period, Noor Abou-Saab filed 349 ADA website cases in the Southern District of New York and 56 in the Eastern District – that's 405 total cases in 24 months, or roughly one new lawsuit every other business day.

The Saab Plaintiff Roster

Like Levy, Saab works with a consistent stable of plaintiffs:

• Tonimarie Rhone – Perhaps Saab's most prolific plaintiff, Rhone has filed cases against companies ranging from small online boutiques to major brands like ZO Skin Health.

• Yanilza Gonzalez – Another serial filer in Saab's network, with dozens of cases following the same template pattern.

• Randy Sanchez – Rounds out the trio of Saab's most active plaintiffs.

What sets Saab's operation apart is the systematic way these cases resolve. Rather than messy trials or drawn-out litigation, Saab's cases typically end in consent decrees – formal agreements where the defendant admits no wrongdoing but agrees to fix their website and, crucially, pay attorney's fees and damages.

The Consent Decree Factory

Take the case of Rhone v. ZO Skin Health, Inc. The publicly available consent decree shows how these arrangements typically work:

• The defendant agrees to remediate their website to conform with WCAG 2.0/2.1 standards within 24 months • The court retains jurisdiction for 36 months • A separate, confidential agreement handles the monetary settlement

That last point is crucial. While the public sees a consent decree focused on improving accessibility, behind closed doors, money is changing hands. Industry estimates suggest these settlements typically range from $5,000 to $20,000 for small businesses, with larger companies paying significantly more.

The efficiency of this system is breathtaking. Saab's plaintiffs file complaints with identical language, defendants receive demand letters with standard settlement offers, and within months, another consent decree is filed with the court. Rinse and repeat, hundreds of times per year.

This isn't advocacy – it's an assembly line. And it's incredibly profitable. If even half of those 405 cases resulted in settlements averaging $15,000, that's over $3 million in settlements generated in just two years, not counting attorney's fees awards.

For businesses looking to avoid becoming another statistic in Saab's consent decree factory, TestParty's automated scanning tools can identify and fix the exact violations these serial plaintiffs look for. As TestParty's case studies show, proactive compliance costs a fraction of what you'll pay in a settlement – and actually improves your website's accessibility instead of just making lawyers rich.

Law Offices of Sanjay R. Gohil: The Geographic Expansion Play

While Levy and Saab concentrate their operations in New York, Sanjay Gohil represents something potentially more troubling: the geographic expansion of the ADA website lawsuit model into new territories.

Operating from offices in both Los Angeles and North Carolina, Gohil has found a clever way to expand the playing field. Instead of competing in the crowded New York market, he's brought the serial plaintiff model to the Western District of North Carolina, targeting out-of-state businesses whose only connection to the jurisdiction is that their websites can be accessed there.

The Mary Conner North Carolina Campaign

Gohil's primary plaintiff is Mary Conner, and together they've turned the Western District of North Carolina into their personal hunting ground. Public dockets show a pattern of cases that would be remarkable if it weren't so predictable:

• Conner v. Boem, Inc. – targeting an online retailer • Conner v. K&J Management, LLC – going after hospitality businesses • Conner v. Saybone, Inc. – suing Capitol clothing boutique's website • Conner v. Vestique, LLC – another fashion retailer in the crosshairs

Each complaint follows the same template we've seen from Levy and Saab's plaintiffs: Conner is visually impaired, she uses screen reader software, she attempted to use the defendant's website, and she encountered barriers. The only things that change are the defendant's name and URL.

The Shaked Law Group Connection

What's particularly interesting about Gohil is his connection to the broader ADA plaintiff network. Court documents show that Gohil has partnered with Shaked Law Group – one of the established players in the ADA website lawsuit space – on cases like the Dollar General website class action.

This collaboration reveals how the ADA plaintiff bar operates less like independent law firms and more like a coordinated network, sharing plaintiffs, strategies, and even template complaints across state lines. It's a franchise model for litigation, and Gohil has bought into the North Carolina territory.

The geographic expansion strategy is brilliant in its cynicism. By filing in North Carolina, Gohil can target businesses nationwide while avoiding the increasingly crowded New York courts. And because defending a lawsuit in North Carolina is expensive and inconvenient for out-of-state businesses, the pressure to settle quickly is even greater.

The Template Playbook: How Cookie-Cutter Complaints Generate Real Money

If you've made it this far, you might be wondering: how can these firms file so many lawsuits so quickly? The answer lies in the ruthless efficiency of their template system.

Pull up any complaint from Levy, Saab, or Gohil's firms, and you'll find the same structure:

Introduction: "This is a civil rights action brought by Plaintiff, a visually-impaired and legally blind individual, against Defendant seeking injunctive relief..."

Parties: "Plaintiff is a visually-impaired and legally blind person who requires screen reading software to read website content and access the internet..."

Jurisdiction: "This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331..."

The Website Barriers: A list of technical violations that reads like a checklist: • Missing alternative text for images • Empty links that contain no text • Redundant links • Lack of adequate labels for forms

The only original writing in most of these complaints is literally filling in the blanks: defendant name, website URL, and perhaps a sentence or two about what the defendant sells. Everything else is copied and pasted.

The Demand Letter Assembly Line

Before a lawsuit is even filed, most targets receive a demand letter. While we haven't seen the specific letters from Levy, Saab, or Gohil's firms, the industry standard template is well documented. These letters typically:

• Identify specific WCAG violations on the website
• Cite the ADA and relevant state laws
• Demand immediate remediation
• Suggest a monetary settlement to avoid litigation
• Set a tight deadline for response (usually 30 days or less)

The genius of this system is its scalability. A single paralegal can generate dozens of demand letters per day, each one potentially worth thousands in settlement fees. It's the legal equivalent of spam email, except the cost of not responding can bankrupt your business.

TestParty's research has found that many businesses receiving these letters have relatively minor accessibility issues that could be fixed quickly and cheaply. But the letters create such fear and urgency that business owners often pay settlements just to make the problem go away.

Jurisdiction Shopping: How Geography Becomes a Weapon

One of the most troubling aspects of the Levy-Saab-Gohil playbook is how they weaponize geography to maximize their leverage.

The New York Advantage

There's a reason why Levy and Saab file almost exclusively in New York federal courts. Beyond the federal ADA claims, New York State Human Rights Law and New York City Human Rights Law provide additional causes of action with their own damages provisions. This creates a "stack" of potential liability that makes settlements more attractive than fighting even weak cases.

The concentration is stunning: according to EcomBack's data, New York federal courts see more ADA website lawsuits than California and Florida combined. This isn't because New York businesses are particularly bad at accessibility – it's because New York law makes these lawsuits particularly profitable.

The North Carolina Experiment

Gohil's North Carolina strategy represents an evolution of the jurisdiction shopping model. By finding a plaintiff (Mary Conner) who resides in North Carolina, Gohil can sue any business whose website is accessible from that state – which is to say, every business with a website.

This creates an impossible situation for defendants. A small business in Oregon suddenly finds itself defending a federal lawsuit in North Carolina, facing the choice between: • Hiring local counsel and fighting a case thousands of miles away • Paying for their existing lawyer to get admitted pro hac vice in North Carolina • Simply settling to make the problem go away

Guess which option most small businesses choose?

The Venue Trap

The truly insidious part of this geographic strategy is how it compounds the settlement pressure. When you're sued in your home jurisdiction, you might fight back. When you're sued across the country by a plaintiff you've never heard of, represented by a firm that files hundreds of these cases, the math changes dramatically.

Defense costs alone can exceed the settlement demand. Travel costs, local counsel fees, and the disruption to your business make fighting back economically irrational, even if you're in the right. The plaintiffs' firms know this, and they price their settlements accordingly – high enough to be profitable, low enough that fighting doesn't make sense.

How to Prepare Before These Firms Find You

If you've read this far, you're probably wondering: what can I do to avoid becoming the next victim? The good news is that these serial plaintiffs are predictable. They look for the same violations, target the same industries, and follow the same patterns. With proper preparation, you can make yourself a much less attractive target.

Step 1: Understand Your Risk Profile

Not all businesses face equal risk. Based on filing patterns, you're at highest risk if you:

• Operate in e-commerce, especially fashion, beauty, or lifestyle products
• Use popular platforms like Shopify or WooCommerce
• Have never conducted a formal accessibility audit
• Target consumers in New York, California, Florida, or North Carolina
• Generate enough revenue to make a settlement worthwhile

If you check multiple boxes, it's not a matter of if you'll be targeted, but when.

Step 2: Fix the Lawsuit Magnets First

Serial plaintiffs look for specific, easy-to-find violations that courts have consistently recognized. TestParty's automated scanner can identify these in minutes:

• Images without alt text – The number one violation cited in complaints
• Missing form labels – Especially on checkout and contact forms
• Keyboard navigation issues – Users must be able to navigate without a mouse
• Missing skip links – Allow users to bypass repetitive navigation
• Poor color contrast – Text must be readable for users with low vision

These aren't just technical requirements – they're the tripwires that serial plaintiffs use to identify targets. Fix them, and you immediately become less attractive for quick-settlement lawsuits.

Step 3: Implement Continuous Monitoring

The cruel irony of ADA website lawsuits is that fixing your site today doesn't protect you tomorrow. Every update, every new product photo, every design tweak can introduce new violations. That's why TestParty's continuous monitoring approach is essential – it catches issues before the plaintiffs do.

TestParty's case study with Thread Wallets shows the value of this approach. As their team noted, they were tired of reacting to accessibility issues. By implementing continuous monitoring, they moved from defense to offense, fixing problems before they could become lawsuits.

Step 4: Document Everything

If you do receive a demand letter or lawsuit, documentation becomes your best friend. Courts are increasingly skeptical of serial plaintiffs, but only if defendants can show good faith efforts at compliance. This means maintaining:

• Records of accessibility audits and remediation efforts
• Documentation of your accessibility policy and procedures
• Evidence of ongoing monitoring and improvement
• Training records showing your team takes accessibility seriously

TestParty's platform automatically maintains this documentation, creating an audit trail that can be invaluable if you're ever targeted. As the Greatness Wins case study demonstrates, having this documentation ready can transform a potential lawsuit into a non-event.

Step 5: Have a Response Plan Ready

Despite your best efforts, you might still receive a demand letter. When that happens, every day counts. Have a plan ready:

• Don't panic – These letters are designed to create fear and urgency
• Don't ignore it – That only makes things worse
• Contact counsel immediately – But choose someone familiar with ADA website cases
• Assess your actual exposure – Run an audit to see if the claimed violations are real
• Consider your options – Settlement isn't always the best choice

If you're already a TestParty customer, you have a powerful advantage: evidence of active remediation. Courts and opposing counsel take defendants more seriously when they can show ongoing compliance efforts, not just panic fixes after being sued.

The DIY Research Checklist: Verify Everything Yourself

Knowledge is power, especially when dealing with serial plaintiffs. Here's how to research any demand letter or lawsuit you receive:

Check the Plaintiff's History

Start by searching the plaintiff's name on Karlin Law's ADA plaintiff database. This will show you:

• How many lawsuits they've filed
• Which law firm represents them
• What types of businesses they typically target

If you find dozens or hundreds of cases, you're dealing with a serial plaintiff.

Research the Law Firm

Look up the law firm on tracking sites to understand their patterns:

• How many ADA website cases have they filed?
• What's their typical settlement range?
• Do they actually take cases to trial, or always settle?

The answers will inform your response strategy.

Compare Your Complaint to Others

If you've been sued, pull up other complaints from the same plaintiff and firm. You'll likely find that your complaint is virtually identical to dozens of others, with only the defendant information changed. This cookie-cutter approach can actually work in your favor – courts are increasingly skeptical of plaintiffs who file identical complaints against dozens of businesses.

Document the Timeline

Serial plaintiffs often claim they tried to use multiple websites on the same day, discovering similar violations on each one. Document these patterns – they can be powerful evidence that the plaintiff isn't a genuine customer but a professional tester.

The Real Cost of the ADA Lawsuit Gold Rush

As we've documented, Gabriel Levy, Noor Saab, and Sanjay Gohil have collectively filed hundreds of ADA website lawsuits, extracting millions in settlements from businesses large and small. But the real cost goes beyond the settlement checks.

Every dollar paid to settle a cookie-cutter lawsuit is a dollar not spent on genuine accessibility improvements. Every small business owner who pays a quick settlement to make a lawsuit go away is one less advocate for actually making the web more accessible. The serial plaintiff model doesn't create a more inclusive internet – it creates a protection racket where businesses pay for peace, not progress.

The tragedy is that real accessibility isn't that hard or expensive. TestParty's platform can identify and help remediate the vast majority of accessibility issues for a fraction of what businesses pay in settlements. Companies like Pasito achieved WCAG 2.2 AA compliance in under two weeks, while WestPoint Home found cost-effective compliance that actually improved their user experience for everyone.

Moving Forward: From Reaction to Prevention

The serial plaintiff gold rush shows no signs of slowing down. As long as there's money to be made from quick settlements, firms like those run by Levy, Saab, and Gohil will continue to thrive. But that doesn't mean your business has to become their next target.

The key is to shift from reaction to prevention. Instead of waiting for a demand letter, take proactive steps to ensure your website is accessible. Instead of viewing accessibility as a legal burden, see it as an opportunity to reach more customers and provide better experiences for everyone.

TestParty's free accessibility scan is a good place to start. In minutes, you'll know whether your site has the kinds of violations that attract serial plaintiffs. More importantly, you'll have a roadmap for fixing them before they become lawsuit fodder.

The choice is stark but simple: you can pay a little now for genuine accessibility, or pay a lot later in legal settlements that don't actually make your site more accessible. The serial plaintiffs are betting you'll choose the latter.

Prove them wrong.

Not sure if your website is at risk? Get a free accessibility scan from TestParty and find out in minutes. For comprehensive protection against serial ADA plaintiffs, explore TestParty's full platform – because real accessibility compliance costs less than a single settlement.