Sullivan Jr. v. Prometheus Global Media LLC Docket Item 1. LEE LITIGATION GROUP, PLLC. C. K. Lee (CL 4. 08. Anne Seelig (AS 3. East 3. 9th Street, Second Floor. New York, NY 1. 00. Tel.: 2. 12- 4. 65- 1.

Fax: 2. 12- 4. 65- 1. Attorneys for Plaintiff and the Class UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK PHILLIP SULLIVAN JR, on behalf of himself and all others similarly situated, Case No.: Plaintiff, CLASS ACTION COMPLAINT - against- PROMETHEUS GLOBAL MEDIA LLC, Defendant, Plaintiff, PHILLIP SULLIVAN JR (hereinafter, “Plaintiff”), on behalf of himself and others similarly situated, by and through his undersigned attorney, hereby files this Class Action Complaint against Defendant, PROMETHEUS GLOBAL MEDIA LLC, and states as follows: INTRODUCTION 1.

This class action seeks to put an end to systemic civil rights violations committed by Defendant PROMETHEUS GLOBAL MEDIA LLC (hereafter collectively as “PGM” or “Defendant”), against the deaf and hard of hearing individuals in New York State and across the United States. Defendant is denying the deaf and hard of hearing individuals throughout the United States equal access to the goods and services PGM provides to non- disabled individuals through http: //www.

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Hollywoodreporter. Case 1: 1. 7- cv- 0. Document 1 Filed 0. Page 1 of 2. 42 or “the website”). Hollywoodreporter. PGM. Yet, Hollywoodreporter. In fact, the access barriers make it impossible for deaf and hard of hearing users to comprehend the audio portion of videos that are posted on Hollywoodreporter.

PGM thus excludes the deaf and hard of hearing from the full and equal participation in the growing Internet economy that is increasingly a fundamental part of the common marketplace and daily living. In the wave of technological advances in recent years, assistive technology is becoming an increasingly prominent part of everyday life, allowing deaf and hard of hearing people to fully and independently access a variety of services, including accessing online videos. Plaintiff Philip Sullivan Jr, who currently lives in New York City, is a deaf and hard of hearing individual. He brings this civil rights class action against Defendant for failing to design, construct, and/or own or operate a website that is fully accessible to, and independently usable by, deaf and hard of hearing people. Approximately 3. 6 million people in the United States are deaf or hard of hearing.

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Many of these individuals require captioning to meaningfully comprehend the audio portion of video content. Just as buildings without ramps bar people who use wheelchairs, video content without captions excludes deaf and hard of hearing individuals. Closed captioning is a viewer activated system that displays text on, for instance, online videos, television programming, or DVD movies. This is different from open captioning or subtitles, which are burned into the video file and automatically displayed for everyone to see, such as subtitles in foreign language movies. With closed captioning, deaf and hard of hearing Case 1: 1. Document 1 Filed 0. Page 2 of 2. 43 individuals have the opportunity to watch videos by reading the captioned text.

Deaf and hard of hearing people watch videos just as sighted people do. The lack of closed captioning means that deaf and hard of hearing people are excluded from the rapidly expanding internet media industry and from independently accessing videos posted on Hollywoodreporter. Despite readily available accessible technology, such as the technology in use at other heavily trafficked websites, which makes use of closed captioning for hearing impaired individuals, such as You. Tube and Netflix, Defendant has chosen to post videos without closed captioning that are inaccessible to deaf and hard of hearing individuals. Without closed captioning, deaf and hard of hearing people cannot comprehend the audio portion of the videos on Hollywoodreporter. By failing to make the website accessible to deaf and hard of hearing persons, Defendant is violating basic equal access requirements under both state and federal law. Congress provided a clear and national mandate for the elimination of discrimination against individuals with disabilities when it enacted the Americans with Disabilities Act.

Such discrimination includes barriers to full integration, independent living, and equal opportunity for persons with disabilities, including those barriers created by websites and other public accommodations that are inaccessible to deaf and hard of hearing individuals. Similarly, New York state law requires places of public accommodation to ensure access to goods, services and facilities by making reasonable accommodations for persons with disabilities. Plaintiff browsed and intended to watch the videos on PGM’s website. However, unless Defendant remedies the numerous access barriers on the website, Plaintiff and Class Case 1: 1. Document 1 Filed 0. Page 3 of 2. 44 members will continue to be unable to independently watch videos on Hollywoodreporter. This complaint seeks declaratory and injunctive relief to correct PGM’s policies and practices to include measures necessary to ensure compliance with federal and state law and to include monitoring of such measures, to update and remove accessibility barriers on Hollywoodreporter.

Plaintiff and the proposed Class and Subclass individuals who are deaf and hard of hearing will be able to independently and privately view videos posted on Defendant’s website. Kicking Off Full Movie Online Free. This complaint also seeks compensatory damages to compensate Class members for having been subjected to unlawful discrimination. JURISDICTION AND VENUE 1.

This Court has subject matter jurisdiction of this action pursuant to: a. U. S. C. § 1. 33. U. S. C. § 1. 21. Plaintiff’s claims arising under Title III of the Americans with Disabilities Act, 4. U. S. C. § 1. 21. ADA”); and b. 2. 8 U. S. C. § 1. 33. 2, because this is a class action, as defined by 2.

U. S. C § 1. 33. 2(d)(1)(B), in which a member of the putative class is a citizen of a different state than Defendant, and the amount in controversy exceeds the sum or value of $5,0. See 2. 8 U. S. C. This Court has supplemental jurisdiction pursuant to 2. U. S. C. § 1. 36. Plaintiff’s pendent claims under the New York State Human Rights Law, N. Y. Exec. Law, Article 1. Watch Pimp Online Hollywoodreporter.

Executive Law § 2. New York City Human Rights Law, N. Y. C. Administrative Code § 8- 1. City law”). 1. 2. Venue is proper in the Southern District of New York pursuant to 2. U. S. C. §§ Case 1: 1.

Document 1 Filed 0. Page 4 of 2. 45 1.

NFL TV Ratings Slide Worries Wall Street. NFL's ratings woes continued in Week 2, and Wall Street is taking notice, given there are fewer excuses for falling viewership than there were a year ago when Hillary Clinton and Donald Trump were distracting TV- watching Americans. While NFL games remain some of the most- watched content on television, ratings slid 1. NFL's opening weekend, with many blaming Hurricane Irma. But without dramatic weather, the second weekend was off 1. This comes after an 8 percent ratings slump last season.

Guggenheim Securities analyst Michael Morris said he had been optimistic heading into the new season because audiences would appreciate some changes, including fewer commercial breaks and allowing players to creatively celebrate touchdowns. Now, though, he says, "early results do not support this optimism."Jefferies analyst John Janedis figures CBS, ESPN, Fox and NBC will generate about $2. NFL advertising revenue this season, but a 1. Since the NFL season opened Sept. NBC parent Comcast are off 9 percent, ESPN parent Disney has seen its stock drop 3 percent and shares of CBS are down 5 percent. Only shares of 2.

Century Fox have risen in that time frame, up 2 percent."Continued declines in NFL ratings again this season will likely place further downward pressure on media stocks," said Morris. He added, in fact, that "the NFL is an indicator of overall primetime programming ratings performance."Pundits, meanwhile, continue to opine on the reason for the fall, with some trying mightily to dismiss a J. D. Power survey in July that put most of the blame on players who protest the National Anthem, the most prominent of them being Colin Kaepernick, who does not currently play for an NFL team. That survey indicated 3. Broadcasters know it's a storyline that has continued into the current season and the networks usually point their cameras at the players who kneel during the anthem. The second- most cited reason for tuning in less was "game delays, including penalty flags" (2. The league and broadcasters have cut back on ads but domestic violence is front and center in 2. Dallas Cowboys superstar running back Ezekiel Elliott.

The league alleges Elliott physically abused a former girlfriend and is trying to suspend him for six games while representatives for Elliott are duking it out with the NFL in courtrooms, generating headlines every step of the way. Way down on the list of survey results is the bugaboo that has been distressing all Hollywood lately: "cord cutting, i.

TV." That answer was cited 6 percent of the time on the J. D. Power survey. Consumers without cable or satellite package can still view NFL games via streaming on online services like CBS All Access, Sling TV, Amazon Prime and the like, which, of course, siphons viewers away from traditional outlets."When the dust settles, it looks like the (virtual pay- TV providers) may have gained more traction than consensus expectations, even with modest marketing spend," Janedis said. It's not all doom and gloom of course. Last year, 3. 1 of the Top 1. TV were NFL games, and Michael Nathanson of Moffett.

Nathanson predicted last week that NBC's Sunday Night Football and ESPN's Monday Night Football would grow their audiences this year over last year based on better matchups. Fox, meanwhile, says viewership for its Cowboys vs. Denver Broncos game Sunday, which was delayed due to lightning, was up 1. And 1. 2. 3 million viewers ages 1. Detroit Lions beat the New York Giants on Monday, up from 1. Monday Night Football on ESPN a week prior. Plus, NFL Network says its Thursday Night Football broadcast of the Houston Texans beating the Cincinnati Bengals drew 8.

Thursday night games on the network last year. The exclusive presentation of that contest was also the most- streamed regular season game ever across NFL Mobile by Verizon and the NFL's digital properties. Also working in favor of the NFL and its broadcast partners is an explosion in the popularity of fantasy sports. According to the Fantasy Sports Trade Association, 5. U. S., with 6. 6 percent of them playing fantasy football — and they watch NFL games and visit websites like ESPN. CBSSports. com far more frequently than those who do not play fantasy.