A Declaratory Judgment that at the commencement of this action CANDLELIGHT DINNER PLAYHOUSE LLC was in violation of the specific requirements of Title III of the ADA described above, and the relevant implementing regulations of the ADA, in that CANDLELIGHT DINNER PLAYHOUSE LLC took no action that was reasonably calculated to ensure that its Website is fully accessible to, and independently usable by, individuals with visual disabilities.Plaintiff asserts the following cause(s) of action in its Complaint: The name and role of all UI elements cannot be programmatically determined things that can be set by the user cannot be programmatically set and/or notification of changes to these items is not available to user agents, including assistive technology.In content implemented using markup languages, elements do not always have complete start and end tags, are not nested according to their specifications, may contain duplicate attributes, and IDs are not always unique.A correct reading sequence is not provided on pages where the sequence in which content is presented affects its meaning.A mechanism is not always available to bypass blocks of content that are repeated on multiple web pages.Text cannot be resized up to 200 percent without assistive technology so that it may still be viewed without loss of content or functionality.Labels or instructions are not always provided when content requires user input.The human language of each passage or phrase in the content cannot be programmatically determined.The default human language of each web page cannot be programmatically determined.Keyboard user interfaces lack a mode of operation where the keyboard focus indicator is visible.Headings and labels do not describe topic or purpose.Web pages lack titles that describe their topic or purpose.The purpose of each link cannot be determined from the link text alone or from the link text and its programmatically determined link context.The Website does not provide a text equivalent for every non-text element.The Website also contains a host of broken links.Many features on the Website also fail to Add a label element or title attribute for each field.Many features on the Website lacks alt.
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