Settlements & Consent Agreements

This database contains notable web accessibility and privacy settlements, consent agreements, and enforcement outcomes from DOJ, FTC, state attorneys general, and private litigation.

Settlement Trends

Web accessibility settlements typically require WCAG 2.1 Level AA compliance within 18-24 months, annual audits, accessibility policies, staff training, and civil penalties ranging from $50,000 to several million dollars depending on organization size and violation severity.

Settlement Statistics

$350K

Average private ADA settlement

18-24

Months typical remediation period

3-5

Years typical monitoring period

95%

Cases settle before trial

DOJ Accessibility Settlements

Organization Sector Year Penalty Key Terms
H&R Block Financial Services 2014 $100,000 Tax preparation website accessibility, screen reader compatibility
Peapod Retail/Grocery 2014 $100,000 Online grocery ordering accessibility
Louisiana Tech University Education 2013 N/A Course materials, LMS accessibility
Carnival Cruise Lines Travel 2015 $55,000 Booking system accessibility, accessibility information
Major Hotel Chain Hospitality 2023 $150,000 Reservation system, accessible room information
State University System Education 2024 $75,000 Systemwide web accessibility, LMS compliance

Major Private Lawsuit Settlements

Defendant Sector Year Settlement Significance
Target Corporation Retail 2008 $6 million Landmark case establishing e-commerce ADA liability
Netflix Entertainment 2012 $755,000 Closed captioning for streaming content
Scribd Technology 2015 $85,000 E-book platform accessibility
Domino's Pizza Food Service 2022 Undisclosed Supreme Court declined certiorari; website/app ADA coverage confirmed
Major Fashion Retailer Retail 2023 $1.5 million Website and mobile app accessibility
Insurance Company Financial 2024 $750,000 Quote and application process accessibility

FTC Privacy Settlements

Company Year Penalty Violation
Meta (Facebook) 2019 $5 billion Cambridge Analytica privacy violations
Epic Games 2022 $520 million COPPA violations, dark patterns
Amazon (Ring) 2023 $30.8 million Privacy and security failures
Amazon (Alexa) 2023 $25 million Children's privacy, data retention
Microsoft (Xbox) 2023 $20 million COPPA violations
Zoom 2020 N/A Deceptive security claims (consent order)

State Privacy Law Settlements

Company State(s) Year Settlement Law
Google 40 States 2022 $391.5 million Location tracking deception
Facebook Illinois 2020 $650 million BIPA (biometric data)
TikTok Illinois 2021 $92 million BIPA (biometric data)
Sephora California 2022 $1.2 million CCPA (first enforcement action)
Google California 2023 $93 million Location privacy violations
DoorDash California 2024 $375,000 CCPA consumer rights violations

Common Settlement Requirements

Accessibility Settlements
  • Achieve WCAG 2.1 or 2.2 Level AA within 12-24 months
  • Annual third-party accessibility audits
  • Publish accessibility statement
  • Designate accessibility coordinator
  • Staff training program
  • Accessible feedback mechanism
  • Vendor accessibility requirements
  • Monitoring period (3-5 years)
  • Civil penalty payment
  • Plaintiff attorney's fees
Privacy Settlements
  • Implement privacy program
  • Biennial third-party privacy assessments
  • Update privacy policies
  • Designate privacy officer
  • Employee training
  • Consumer redress fund
  • Delete improperly collected data
  • Honor opt-out requests
  • 20-year monitoring (FTC)
  • Civil penalties

Education Sector Resolutions (OCR)

The Department of Education Office for Civil Rights has resolved numerous accessibility complaints:

Institution Year Issues Resolution
University of California Berkeley 2016 Online course accessibility Removed thousands of inaccessible videos
MIT/Harvard (edX) 2015 MOOC accessibility Comprehensive accessibility plan
University of Montana 2012 ICT accessibility Systemwide accessibility policy
Penn State University 2010 E-reader accessibility Accessible technology procurement policy
Settlement Trends

$350K+

Average accessibility settlement

18-24 mo

Typical remediation timeline

Related Resources
Prevention

The best settlement is one you never need. Proactive compliance is far less expensive than reactive remediation.

Compliance Guide