On April 1, 2015, in a decision of significance to all businesses with an Internet presence, the Ninth Circuit held a website-only business (i.e., unconnected to any physical place open to the public) is not a “place of public accommodation” subject to Title III of the Americans with Disabilities Act.

This is the first time a federal appellate court has resolved this important issue. In reaching its decision, the Ninth Circuit relied on its prior cases, and those of the Third and Sixth Circuits, which generally hold that Title III applies only to businesses that operate real physical spaces open to the public.

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