Serial ADA Plaintiffs: The 2026 Filing Data by Firm and Venue

Last updated: September 22, 2026. This article is general information compiled from public court-tracking reports and published court decisions. It is not legal advice. Nothing here describes the motives of any law firm or plaintiff, and a filing count says nothing about the merits of any individual case. If you have received a demand letter or a complaint, consult a licensed attorney.

A serial ADA plaintiff is an individual who has filed repeated website accessibility lawsuits, usually represented by one of a small number of firms that concentrate in this practice area. Filing many suits is lawful. What the 2025 and 2026 tracking data shows is how concentrated the filing base has become: a handful of firms and a few dozen plaintiffs account for most digital accessibility cases nationwide.

Key numbers: Equal Access Law Group, PLLC filed 641 website accessibility lawsuits in 2025 — 16.24% of the 3,948 filed nationally, more than any other firm (EcomBack 2025 annual report). Sixteen plaintiff firms filed 3,567 of those cases, or 90.35% of the national total (EcomBack). UsableNet's 2026 midyear report finds the 10 most active plaintiff firms account for roughly 84% of filings, and that approximately 20 to 25 plaintiffs bring most digital accessibility lawsuits. Plaintiffs filed 3,117 federal website accessibility lawsuits in 2025, a 27% rebound over 2024 (Seyfarth Shaw). UsableNet projects roughly 6,000 digital accessibility lawsuits in 2026, 20–25% above 2025.

What is a serial ADA plaintiff?

A serial ADA plaintiff is a person who has filed many accessibility lawsuits — in some documented instances, hundreds. The term is descriptive rather than a legal category: nothing in the Americans with Disabilities Act caps how many actions one plaintiff may bring.

Many of these plaintiffs are described in filings as "testers" — people who visit a website specifically to check whether it complies with accessibility requirements, rather than to buy something. Under Title III of the ADA, a private plaintiff can obtain injunctive relief and, as a prevailing party, attorney's fees under 42 U.S.C. § 12205 — but not money damages. Damages, where they appear, come from state statutes pleaded alongside the federal claim, such as California's Unruh Civil Rights Act or New York's state and city human rights laws. That structure is the mechanical reason so much of this litigation clusters in a few states.

How have courts handled serial-plaintiff standing?

Courts have split. The Supreme Court took up the question in Acheson Hotels, LLC v. Laufer but dismissed the case as moot in December 2023 without deciding whether an ADA tester who never intends to visit a business has Article III standing.

The Court vacated the First Circuit's judgment and remanded with instructions to dismiss the case as moot, noting that the plaintiff had voluntarily dismissed her pending suits. The majority opinion recorded that she "has sued hundreds of hotels"; a separate opinion by Justice Thomas put the figure at over 600 lawsuits in five years. Because the Court resolved the case on mootness, it expressly did not reach the standing question, and lower courts continue to apply their own circuit precedent. The practical consequence for a defendant is that standing is litigated case by case, on the specific injury a particular plaintiff alleges — not settled nationally.

Which firms file the most website accessibility lawsuits?

Five firms accounted for 60.21% of the 3,948 website accessibility lawsuits filed in the United States in 2025, and 16 firms accounted for 90.35%, according to EcomBack's 2025 annual report.

+------------------------------------+----------------------------------------+---------------------------------------+
|           Plaintiff firm           |   2025 website accessibility filings   |   Share of the 3,948 national total   |
+------------------------------------+----------------------------------------+---------------------------------------+
|    Equal Access Law Group, PLLC    |                  641                   |                 16.24%                |
+------------------------------------+----------------------------------------+---------------------------------------+
|          Manning Law, APC          |                  615                   |                 15.58%                |
+------------------------------------+----------------------------------------+---------------------------------------+
|       Gottlieb & Associates        |                  468                   |                 11.85%                |
+------------------------------------+----------------------------------------+---------------------------------------+
|          Stein Saks, PLLC          |                  380                   |                 9.63%                 |
+------------------------------------+----------------------------------------+---------------------------------------+
|   Roderick V. Hannah, Esq., P.A.   |                  273                   |                 6.91%                 |
+------------------------------------+----------------------------------------+---------------------------------------+
|       Top 16 firms combined        |                 3,567                  |                 90.35%                |
+------------------------------------+----------------------------------------+---------------------------------------+

Source: EcomBack 2025 annual ADA website accessibility lawsuit report.

Three independent trackers using different methodologies reach the same structural finding. Seyfarth Shaw found the top 15 plaintiff firms accounted for 86.76% of federal ADA Title III filings in 2024. UsableNet's 2026 midyear report puts the 10 most active firms at roughly 84% of filings. EcomBack's count above covers website accessibility matters specifically across federal and state courts. Different denominators, same shape: this is a concentrated docket.

Where are these cases filed?

Four states accounted for 86.65% of 2025 website accessibility filings — New York, Florida, California and Illinois — per EcomBack's annual report. Venue is not incidental; it determines which state statute, and therefore which damages exposure, attaches to the federal claim.

+--------------------------+----------------------------------------+-------------------------------+
|          State           |   2025 website accessibility filings   |   Share of national filings   |
+--------------------------+----------------------------------------+-------------------------------+
|         New York         |                 1,108                  |             28.06%            |
+--------------------------+----------------------------------------+-------------------------------+
|         Florida          |                  950                   |             24.06%            |
+--------------------------+----------------------------------------+-------------------------------+
|        California        |                  787                   |             19.93%            |
+--------------------------+----------------------------------------+-------------------------------+
|         Illinois         |                  576                   |             14.59%            |
+--------------------------+----------------------------------------+-------------------------------+
|   Four states combined   |                 3,421                  |             86.65%            |
+--------------------------+----------------------------------------+-------------------------------+

Source: EcomBack 2025 annual report.

Two 2026 shifts are worth tracking. New York led midyear 2026 filings with 1,269 cases, and Illinois has emerged as one of the fastest-growing jurisdictions, per UsableNet's 2026 midyear report. And filings continue moving from federal to state court in New York, California and Florida (UsableNet) — which matters for anyone reading national statistics, because state dockets are harder to compile than federal PACER records, so published federal counts increasingly understate total volume. Seyfarth Shaw's federal tracking recorded 8,667 ADA Title III federal filings in 2025, with pro se filings up 40% year over year.

How many plaintiffs are behind those filings?

Roughly 20 to 25 plaintiffs, working with a relatively small group of law firms, bring most digital accessibility lawsuits, according to UsableNet's 2026 midyear report. EcomBack's 2025 annual report names the highest-volume individual filers by case count.

+----------------------+--------------------------------------+-------------------------------+
|      Plaintiff       |   2025 website accessibility cases   |   Share of national filings   |
+----------------------+--------------------------------------+-------------------------------+
|   Michael Sandoval   |                 241                  |             6.10%             |
+----------------------+--------------------------------------+-------------------------------+
|     Julie Dalton     |                 131                  |             3.32%             |
+----------------------+--------------------------------------+-------------------------------+
|     Perla Mageno     |                 130                  |             3.29%             |
+----------------------+--------------------------------------+-------------------------------+

Source: EcomBack 2025 annual report.

These are counts of filings, published by an industry tracker — not findings about any case, and not a characterization of any plaintiff. It is also worth stating plainly what the numbers do not decide: high filing volume is not itself unlawful, and as the Supreme Court's 2023 disposition in Acheson left in place, whether a repeat tester has standing remains a question courts answer individually. UsableNet separately reports that Equal Access Law Group, PLLC represents more than a dozen individual plaintiffs, which is the mechanical explanation for how one firm reaches several hundred filings a year.

What does the concentration mean if you are a defendant?

Concentration makes claims predictable. When 16 firms file 90% of cases, the pleaded barriers, the venues, the state-law add-ons and the settlement ranges repeat — and a response can be built against a known pattern rather than improvised.

The recurring allegation set across these complaints is narrow: missing image alt text, empty or unlabeled links and buttons, form fields without labels, menus that cannot be operated by keyboard, and no mechanism to skip repeated navigation blocks. In TestParty's audits of Shopify stores, most of those are exactly the failures an automated scanner surfaces on a first pass of a homepage and product page — which is consistent with high-volume filing practices identifying candidates efficiently.

Knowing which firm signed your letter narrows the rest quickly: likely venue, likely statutes, and how the matter has historically progressed. We maintain firm-level detail for two of the most active filers — see the response guides for Equal Access Law Group demand letters and Mizrahi Kroub demand letters, which UsableNet's 2025 year-end report ranked first among plaintiff firms by digital accessibility case volume. For the stage after a complaint is docketed, the ADA website lawsuit defense playbook covers exit paths, and the line-item cost breakdown covers what settlement and defense actually total.

Which businesses get named?

Ecommerce dominates the defendant list. Seyfarth Shaw puts ecommerce at 69–77% of website accessibility cases, and UsableNet's 2026 midyear report puts ecommerce at approximately 80% of digital accessibility lawsuits.

EcomBack's 2025 category breakdown is more granular: restaurants, food and beverage accounted for 1,368 suits (34.65%), lifestyle, fashion and apparel for 1,025 (25.96%), and beauty and personal care for 317 (8.03%). Company size is not much protection — Seyfarth Shaw reported that 67% of 2024 defendants had under $25 million in revenue.

Being sued once does not remove a business from the pool. UsableNet's 2026 midyear report finds approximately one-quarter of digital accessibility lawsuits are filed against companies that have previously faced a similar claim, and Seyfarth Shaw's tracking found repeat defendants in 46% of H1 2025 federal cases. Settling without remediating leaves the same scannable failures live for the next scan.

What prevention posture actually reduces exposure?

The posture that holds up has three parts: fix the violations in the source code, monitor continuously so regressions are caught before someone else's scanner finds them, and keep dated records of both.

As of August 2026, TestParty has remediated more than 35 million accessibility issues across customer stores, with initial remediation completed in 14 days and ongoing daily AI scans plus monthly expert manual audits producing date-stamped compliance reports. In the history of the company, fewer than 1% of TestParty customers have been named in accessibility lawsuits while on the platform. By contrast, based on TestParty's analysis of Court Listener records, more than 1,000 businesses with accessibility widgets installed were named in lawsuits in 2024 — widgets layer over the page rather than fixing the markup these complaints describe.

The documentation is half the value, because it converts engineering work into something counsel can put in front of the other side. In one public TestParty matter, a documented source-code remediation supported settling a $74,999 demand for $2,000 (Dorai Home). Our guide to the accessibility compliance records to keep on file covers what to have ready before a letter arrives.

Frequently Asked Questions

Is serial ADA filing legal? Yes. Nothing in the ADA limits how many lawsuits an individual may file, and Title III is enforced primarily through private actions by design. Courts have addressed whether particular repeat plaintiffs have Article III standing, but the Supreme Court dismissed Acheson Hotels, LLC v. Laufer as moot in December 2023 without resolving the tester-standing question nationally.

Can I countersue a serial plaintiff? Rarely a practical strategy, and one to raise with counsel rather than assume. Fee-shifting under 42 U.S.C. § 12205 runs mostly one direction in practice: prevailing plaintiffs recover fees, while courts apply a stricter standard before awarding fees to a prevailing defendant in civil rights cases, generally requiring that the claim was frivolous, unreasonable or groundless.

Which firm filed the most website accessibility lawsuits in 2025? Equal Access Law Group, PLLC, with 641 cases — 16.24% of the 3,948 filed nationally — per EcomBack's 2025 annual report. UsableNet's 2025 year-end report ranked Mizrahi Kroub LLP first among plaintiff firms by digital accessibility case volume. The two trackers use different methodologies and case definitions, so their rankings differ.

Does it matter how many suits the plaintiff suing me has filed? It can inform strategy without changing the merits. Filing history is public on court dockets and tells counsel how a plaintiff's prior matters progressed, which venues they use, and what statutes they typically plead. It does not by itself defeat a claim — whether your website has the alleged barriers is the fact question.

Are these lawsuits moving out of federal court? Increasingly, yes. UsableNet reports filings shifting toward state courts in New York, California and Florida. That matters when reading statistics: federal counts, including Seyfarth Shaw's 3,117 federal website accessibility filings in 2025, capture only part of the total, which is why EcomBack's federal-plus-state count for the same year is 3,948.

If I settle, am I done? Not necessarily. Approximately one-quarter of digital accessibility lawsuits name companies that have previously faced a similar claim (UsableNet 2026 midyear report), and Seyfarth Shaw found repeat defendants in 46% of H1 2025 federal cases. Settlement agreements typically include remediation commitments with deadlines; completing and documenting them is what closes the loop.

TestParty practices a cyborg approach to content: AI assists with research and drafting, our accessibility experts validate every claim. This article represents our editorial perspective based on public data as of the publication date. We compete in the digital accessibility space — which means we have informed opinions, but also a vested interest. All sources are cited so you can draw your own conclusions.