The Boilerplate ADA Lawsuit Industry: How Copy-and-Paste ADA Litigation Targets American Businesses

Every day, businesses across America receive nearly identical ADA website lawsuits from a network of 100+ serial plaintiffs and 25+ law firms running a copy-paste litigation mill. TestParty stops these predatory lawsuits before they start with real WCAG 2.2 AA compliance—not the overlay Band-Aids that still leave you vulnerable. Protect your business at testparty.ai/book-a-demo

The Industrial Scale of Website Accessibility Lawsuits

A comprehensive analysis of federal court filings reveals an extensive network of law firms and serial plaintiffs filing nearly identical Americans with Disabilities Act (ADA) lawsuits against businesses across the United States. This investigation examines actual court documents and identifies over 100 plaintiffs and 25+ law firms engaged in what critics call "drive-by litigation" that exploits the ADA for profit rather than advancing accessibility.

For our research, we used 4 major sources:

• Senior v Masimo Corporation
• Ortiz v Daytona International Speedway LLC
• Rice v Tarpley Music Company Inc
• East End Trial Group LLC – Kevin Tucker – Blair Douglass – Example Lawsuit

The Law Firm Network: A Nationwide Operation

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The Major Players

Gottlieb & Associates (PLLC) stands as one of the most prolific filers, operating from 150 East 18th Street, Suite PHR, New York, NY 10003. The firm's attorneys—Michael A. LaBollita, Jeffrey M. Gottlieb, and Dana L. Gottlieb—represent numerous plaintiffs including:

• Denise Crumwell
• Denis Crumwell (possibly same person, different spelling)
• Sylinia Jackson
• Cedric Bishop
• Sandy Graciano
• Donna Hedges
• Henry Tucker
• Braulio Thorne (also represented by Mizrahi Kroub)
• Victor Lopez
• Lawrence Young
• Frank Senior
• Joseph Ortiz

Mars Khaimov Law, PLLC operates extensively in the Eastern and Southern Districts of New York with an impressive roster of plaintiffs:

• Jenny Hwang
• Damon Jones
• Jovan Campbell
• Veronica Maddy
• Lamar Brown
• Andrew Toro
• Jasmine Toro
• Victoria Dicks
• Miriam Cruz

Stein Saks, LLC focuses on the Southern District of New York, representing:

• Jenisa Angeles
• Warren Zinnamon
• Marta Hanyzkiewicz
• Bryan Velazquez
• Daniel Rodriguez
• Marina Iskhakova

Mizrahi Kroub LLP (sometimes spelled Mizrhai Kroub) represents multiple plaintiffs in the Southern District of New York:

• Braulio Thorne (shared with Gottlieb)
• Jose Zarzuela
• Roberta Feliz
• Kathleen Sypert
• Ana Chalas
• Omar Rodriguez
• Vivian Alvarez

The California Connection

Wilshire Law Firm operates in the Southern District of California with plaintiffs:

• Julissa Cota
• Valerie Brooks
• Richard Paul Merrell
• Darren Gresham
• Brett DeSalvo

Pacific Trial Attorneys files in California Superior Court (Los Angeles County):

• Rusty Rendon
• Brittney Mejico
• Dominick Martin

Manning Law, APC targets the Central District of California:

• Biglang-Awa Castro Sheila
• Perla Mageno
• Cesar Cotto

The Florida Network

Acacia Barros, P.A. operates in the Southern District of Florida (Miami Division):

• Aishia Petersen
• Raymond T. Mahlberg

Law Office of Pelayo Duran (Southern District of Florida):

• Nelson Fernandez
• Victor Ariza
• Daniel Moncada

Mendez Law Offices (Diego German Mendez, Esq.) in the Southern District of Florida:

• Alejandro Espinoza

Leal Law Firm (Southern District of Florida):

• Andres Gomez

Other Key Players

• Shaked Law Group: Aretha Crosson, Linda Slade, Marion Kiler, Pedro Martinez, Mary Conner (Eastern District of New York)
• Cohen & Mizrahi LLP: Josue Romero, Shael Cruz, Christian Sanchez (Southern District of New York)
• The Hill Law Firm (Michelle E. Hill, Esq.): Cassandra Wilson (California Superior Court, Los Angeles)
• Zemel Law (Daniel Zemel, Esq.): Carlos Herrera (Superior Court of New Jersey, Hudson County)
• Lipsky Lowe: Brian Fischler, Kareem Nisbett (Eastern District of New York)
• East End Trial Group: EU Directive, Blair Douglass, Kevin Tucker (Western District of Pennsylvania)
• Potter Handy: Chris Langer (Northern District of California)
• Shalom Law: Michelle Tenzer-Fuch (Eastern District of New York)
• Marcus & Zelman: Ramon Jaquez, Irene Hecht (Southern District of New York)
• The Marks Law Firm: Luc Burbon (Eastern District of New York)
• Law Offices of Mitchell Segal: Jay Winegard (Southern District of New York)
• Lawrence H. Fisher: Anthony Hammond Murphy (Western District of Pennsylvania)
• Blaise & Nitschke: Israel Antonio (Northern District Illinois Eastern)
• Nye, Stirling, Hale, Miller & Sweet LLP: Representing Lucas Rice and Christopher Walters (Eastern District of Wisconsin)

Recently added to this list are Gabriel A. Levy, P.C., the Law Offices of Sanjay R. Gohil, and The Law Office of Noor A. Saab, Esq.

Anatomy of a Boilerplate Lawsuit: The Copy-Paste Formula

The Standard Opening

Every lawsuit begins with nearly identical language establishing the plaintiff's visual impairment and citing the same statistics. From the actual filings:

"Plaintiff is a visually-impaired and legally blind person who requires screen-reading software to read website content using [his/her] computer. Plaintiff uses the terms 'blind' or 'visually-impaired' to refer to all people with visual impairments who meet the legal definition of blindness in that they have a visual acuity with correction of less than or equal to 20 x 200."

They then universally cite 2010 Census data: "approximately 8.1 million people in the United States are visually-impaired, including 2.0 million who are blind" and "approximately 400,000 visually-impaired persons live in the State of New York."

The DOJ Letter Citation

Every complaint includes the same September 25, 2018 letter from Assistant Attorney General Stephen E. Boyd to Congressman Ted Budd, quoted verbatim across all filings:

"The Department [of Justice] first articulated its interpretation that the ADA applies to public accommodations' websites over 20 years ago. This interpretation is consistent with the ADA's title III requirement that the goods, services, privileges, or activities provided by places of public accommodation be equally accessible to people with disabilities."

The COVID-19 Pandemic Argument

Remarkably, lawsuits filed as late as 2025 still include identical paragraphs about COVID-19's 2020 impact, showing the copy-paste nature:

"This discrimination is particularly acute during the current COVID-19 global pandemic. According to the Centers for Disease Control and Prevention ("CDC"), Americans living with disabilities are at higher risk for severe illness from COVID-19 and, therefore, are recommended to shelter in place throughout the duration of the pandemic."

The Technical Violations List

Every complaint lists the same accessibility barriers, often in the same order:

1. Lack of Alternative Text (alt-text) for images
2. Empty Links That Contain No Text
3. Redundant Links (adjacent links to same URL)
4. Linked Images Missing Alt-text
5. Broken links to non-existent pages
6. Same title elements on multiple pages
7. Missing labels or instructions for user input
8. Inaccessible PDFs
9. Scripts without text equivalents
10. Forms not properly labeled

These boilerplate complaints list the same accessibility issues that TestParty's AI-powered platform automatically detects and fixes in your source code within 14 days. Stop risking $50,000+ settlements—get compliant for a fraction of the cost. Learn more at testparty.ai

The Shopping Attempt Claims

The complaints follow a predictable pattern where plaintiffs claim they attempted to purchase specific items but were prevented by accessibility barriers. Examples from the actual filings:

• Frank Senior: "attempted to purchase Px7 S3 Headphones from Defendant"
• Joseph Ortiz: "attempted to purchase a product from the Defendant"
• Lucas Rice: "desired to purchase a new MIDI controller"
• Christopher Walters: "wanted to purchase the Bach 180S37 Stradivarius Bb Trumpet Outfit - Silver Plated"

Notably, these attempts are often vague, with minimal detail about the actual shopping experience or genuine interest in the products.

The 13-Point Injunctive Relief Template

Every lawsuit seeks identical relief, demanding defendants:

1. Retain a qualified consultant acceptable to Plaintiff ("Web Accessibility Consultant")
2. Provide biennial web accessibility training for all employees
3. Perform automated accessibility audits on a periodic basis
4. Conduct quarterly end-user testing with blind or low-vision testers
5. Incorporate consultant recommendations within 60 days
6. Create a Web Accessibility Policy with email, instant messenger, and toll-free phone number
7. Add footer statements about accessibility efforts on every page
8. Include feedback mechanisms for accessibility issues
9. Provide notice soliciting feedback on accessibility improvements
10. Distribute policies to all web content personnel and contractors
11. Train at least three customer service representatives specifically for disability assistance
12. Modify bug fix policies to prioritize accessibility issues
13. Allow plaintiff monitoring for up to two years with access to all consultant recommendations

This cookie-cutter relief package essentially mandates expensive ongoing consulting arrangements that often benefit the plaintiffs' attorneys through monitoring fees.

The Jurisdiction Games

The lawsuits employ creative theories to establish personal jurisdiction far from defendants' headquarters. They argue that any online sales to state residents create jurisdiction, citing cases like:

• Reed v. 1-800-Flowers.com, Inc.
• Ford Motor Co. v. Mont. Eighth Judicial Dist. Court
• South Dakota v. Wayfair, Inc.

This allows plaintiffs to file in plaintiff-friendly jurisdictions regardless of where the business is located.

The Accessibility Overlay Trap

Several complaints now reference the FTC's recent action against AccessiBe, which was ordered to pay $1 million for false claims about ADA compliance. The Tarpley Music complaint specifically notes:

"These 'third party scripts... try to detect and fix accessibility problems through AI or machine learning' but 'often miss more than 70% of WCAG guidelines which can only be assessed through manual testing' and 'often override the settings of users' existing assistive technology software, which makes things more difficult.'"

This creates a catch-22: businesses that purchase overlay solutions believing they're achieving compliance still face lawsuits claiming the overlays don't work.

While overlay solutions leave you vulnerable to lawsuits (as the FTC's $1M AccessiBe penalty shows), TestParty delivers true compliance through source code remediation that serial plaintiffs can't challenge. Our 14-day compliance timeline means you're protected before law firms can even draft their next copy-paste complaint. Schedule your demo at testparty.ai/book-a-demo

The Class Action Threat

Many complaints seek class certification for:

• Nationwide classes of all legally blind individuals
• State sub-classes (typically New York)
• City sub-classes (typically New York City)

This multiplies the settlement pressure, as defendants face potential liability to thousands of class members rather than a single plaintiff.

The Business Targets: From Giants to Mom-and-Pops

The lawsuits target businesses of all sizes:

Major Corporations:

• Masimo Corporation (Bowers & Wilkins audio)
• Daytona International Speedway
• NASDAQ (mentioned as prospect)
• Cigna (mentioned as prospect)

Small Businesses:

• Tarpley Music Company (Texas musical instruments)
• Nadri (jewelry/accessories)
• Local restaurants and retailers

Red Flags in the Pattern

Minimal Actual Use

Plaintiffs typically claim only 1-2 visits to websites, with the most recent conveniently just before filing. From Joseph Ortiz's complaint: "During Plaintiff's visits to the Website, the last occurring in September, 2022..."

No Pre-Suit Notice

None of the examined complaints indicate plaintiffs contacted businesses about accessibility before suing, suggesting the goal is litigation rather than accessibility.

Forum Shopping

Plaintiffs file in districts known for favorable outcomes, using minimal online sales to establish jurisdiction thousands of miles from defendants.

The Serial Plaintiff Problem

Many plaintiffs appear in multiple lawsuits. Braulio Thorne, for instance, is represented by both Gottlieb & Associates and Mizrahi Kroub LLP. Some plaintiffs have filed dozens or even hundreds of similar lawsuits.

Copy-Paste Pleadings

Large sections are identical across different cases, different law firms, and different jurisdictions, including:

• Entire paragraphs about COVID-19 (unchanged since 2020)
• Technical descriptions of screen readers
• Legal arguments and case citations
• Even typos and formatting errors

The Settlement Shakedown

The structure of these lawsuits appears designed to force quick settlements:

1. High Defense Costs: Defending can cost $50,000-$100,000+
2. Class Action Risk: Potential liability to thousands multiplies exposure
3. Injunctive Relief Costs: The 13-point plan requires expensive consultants
4. Ongoing Monitoring: Two years of plaintiff oversight adds costs
5. Attorney Fee Shifting: Defendants pay plaintiff attorneys if they lose

Most businesses settle for $10,000-$50,000 rather than risk higher defense costs and potential liability.

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The Real Impact on Accessibility

Critics argue these lawsuits don't improve accessibility because:

• Serial plaintiffs don't genuinely intend to use the websites
• No pre-suit notice prevents businesses from fixing issues voluntarily
• Cookie-cutter demands don't address specific accessibility needs
• Quick settlements often don't include actual accessibility improvements
• Small businesses may shut down online presence rather than risk lawsuits

Legislative and Regulatory Failures

The explosion of these lawsuits stems from:

1. No Clear Standards: The DOJ hasn't adopted specific web accessibility regulations
2. Vague Requirements: "Effective communication" lacks technical specifications
3. No Safe Harbor: Even good-faith compliance efforts don't prevent lawsuits
4. No Notice Requirement: Unlike physical accessibility, no pre-suit notice required

Conclusion: A System in Need of Reform

The evidence reveals an industrial-scale litigation machine where:

• 25+ law firms use identical templates
• 100+ serial plaintiffs file multiple lawsuits
• Thousands of businesses face cookie-cutter demands
• Millions in settlements flow with minimal accessibility improvement

While website accessibility is crucial for disabled Americans, this predatory litigation model undermines the ADA's noble goals. Real reform requires:

1. Clear technical standards from the DOJ
2. Pre-suit notice requirements
3. Safe harbors for good-faith compliance efforts
4. Limits on serial plaintiffs
5. Proportional remedies based on business size

Until then, American businesses remain vulnerable to this boilerplate lawsuit shakedown that enriches lawyers while doing little to actually improve digital accessibility for disabled Americans who genuinely need and deserve equal access to online services.

TestParty offers the real solution: achieve genuine WCAG 2.2 AA and ADA compliance in 14 days, removing the vulnerabilities these serial plaintiffs exploit. Join industry leaders who've eliminated their litigation risk while actually improving accessibility for disabled customers. Get protected at testparty.ai

The ADA was meant to open doors, not to create a litigation trap that forces businesses to choose between expensive settlements and even more expensive defenses. The current system fails everyone—businesses, disabled individuals seeking genuine access, and the justice system clogged with copy-paste complaints. Reform is not just needed; it's essential to preserve both the integrity of the ADA and the ability of businesses to serve all customers online.