https://ogletree.com/insights-resources/blog-posts/websites-are-not-places-of-public-accommodation-subject-to-title-iii-of-the-ada-federal-court-in-new-york-rules/
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Websites Are Not Places of Public Accommodation Subject to Title III of the ADA, Federal Court in New York Rules
In a careful, reasoned decision that deeply explored the meaning of “public accommodation” under the Americans with Disabilities Act (ADA), the chief judge of the U.S. District Court for the Southern District of New York held in Mejia v. High Brew Coffee Inc. that websites and virtual-only businesses are not subject to the requirements of Title III of the ADA. By engaging in this deeper inquiry, the decision seems designed to send a message to the other judges in the district that they, too, should reverse a long-standing trend in the district of permitting claims against web-only businesses.