A legal complaint alleges that an online retailer’s website denies equal access to blind and visually impaired individuals by failing to meet established accessibility standards. The complaint was filed by Victor Lopez on March 17, 2026, in the United States District Court for the Southern District of New York against IP Reserve, LLC.
According to the filing, Victor Lopez brings this action on behalf of himself and all others similarly situated. The lawsuit claims that IP Reserve, LLC operates the NBPure online retail store through its interactive website www.nbpure.com but does not provide full accessibility for people who rely on screen-reading software due to visual impairments. Lopez states he is legally blind and requires such technology to navigate websites independently.
The complaint outlines how public accommodations are required by law to make their websites equally accessible to individuals with disabilities. It references guidance from the U.S. Department of Justice confirming that Title III of the Americans with Disabilities Act (ADA) applies to web content provided by businesses open to the public. The suit cites statistics indicating millions of Americans are visually impaired and asserts that accessible web design is necessary for their participation in modern life.
Lopez alleges that despite these requirements, IP Reserve’s website contains multiple barriers preventing effective use by blind consumers. These include missing alternative text for images, empty or redundant links without descriptive labels, broken links leading to error pages without proper notification from screen readers, and lack of distinct page titles—making navigation difficult or impossible for those using assistive technology like Job Access With Speech (JAWS). Lopez describes specific attempts on February 25, 2026, when he tried unsuccessfully to purchase a Daily Multi-Fiber product due to these obstacles.
The plaintiff argues that these conditions amount to discrimination under several statutes: Title III of the ADA; New York State Human Rights Law (NYSHRL); New York City Human Rights Law (NYCHRL); and New York State General Business Law § 349 (GBL), which prohibits deceptive business practices. He claims these barriers have caused him frustration and humiliation as well as pecuniary loss because he could not comparison shop or obtain complete product information.
The legal filing seeks broad remedies from the court. Lopez requests a permanent injunction requiring IP Reserve, LLC to bring its website into compliance with recognized standards such as the Web Content Accessibility Guidelines (WCAG) 2.0. Specific measures sought include retaining a qualified web accessibility consultant; regular automated and human testing involving users with visual impairments; staff training; implementation of policies for reporting and addressing accessibility issues; posting clear statements about efforts toward accessibility; and allowing ongoing monitoring by plaintiff’s counsel.
In addition to injunctive relief, Lopez asks for compensatory damages—including statutory damages under state law—civil penalties or fines for each offense under both state and city human rights laws, treble damages under GBL § 349(h), reasonable attorneys’ fees and costs, pre- and post-judgment interest, class certification for nationwide as well as New York State and City subclasses of similarly affected individuals, appointment as class representative along with his attorneys as class counsel, and any other relief deemed appropriate by the court.
The complaint names Michael A. LaBollita, Jeffrey M. Gottlieb, and Dana L. Gottlieb of Gottlieb & Associates PLLC as attorneys representing Lopez in this matter. The case is identified as No. 1:26-cv-02215.
Source: 126cv02215_Victor_Lopez_v_IP_Reserve_Complaint_Southern_District_of_New_York..pdf
