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No. 02-16163-BB
IN THE UNITED STATES COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT
_______________
ACCESS NOW, INC., AND ROBERT GUMSON, et al.,
Plaintiffs-Appellants
v.
SOUTHWEST AIRLINES, INC.,
Defendant-Appellee
_______________
ON APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
_______________
BRIEF OF THE WORLD WIDE WEB CONSORTIUM
SUPPORTING THE APPELLANT
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Dated: March 17, 2002 Attorneys for Amicus Curiae
The undersigned counsel of record certifies that, to the best of her knowledge, the following listed persons or entities have an interest in the outcome of this appeal:
Access Now, Inc.,| ______________________________ Deirdre K. Mulligan Jennifer M. Urban Samuelson Law, Technology & Public Policy Clinic University of California at Berkeley School of Law (Boalt Hall) 396 Simon Hall Berkeley, CA 94720-7200? Telephone: (510) 643-4800? Facsimile: (510) 643-4625 |
Dated: March 17, 2003
TABLE OF AUTHORITIES
I. STATEMENT OF IDENTITY AND INTEREST OF AMICUS CURIAE
II. SUMMARY OF ARGUMENT
III. THE WORLD WIDE WEB CONSORTIUM CREATES THE TECHNICAL STANDARDS FOR THE WEB, AND IS THE RECOGNIZED INTERNATIONAL AUTHORITY ON WEB ACCESSIBILITY.
A. THE WORLD WIDE WEB CONSORTIUM IS A LEADING STANDARDS ORGANIZATION.
B. W3C RECOMMENDATIONS ARE STABLE, BROADLY ACCEPTED, AND WIDELY IMPLEMENTED STANDARDS DEVELOPED THROUGH A CONSENSUS PROCESS.
C. THE WORLD WIDE WEB CONSORTIUM’S WEB ACCESSIBILITY INITIATIVE IS THE RECOGNIZED INTERNATIONAL AUTHORITY ON WEB ACCESSIBILITY.
1. The Web Accessibility Initiative’s guidelines constitute well-defined, broadly accepted standards for making Web sites, Web authoring tools, and Web user agents (browsers and media players) accessible to individuals with disabilities and interoperable with assistive technologies.
2. While Web sites, user agents such as browsers and media players, and assistive technologies play complementary roles in achieving an accessible Web, the accessibility of Web sites themselves is the essential starting place.
IV. THE WORLD WIDE WEB HAS BECOME AN ESSENTIAL MEANS OF DELIVERING INFORMATION AND INTERACTION, INCLUDING FOR INDIVIDUALS WITH DISABILITIES.
V. WEB SITES HAVE BECOME STANDARD PRACTICE FOR BUSINESSES AND OTHER ORGANIZATIONS, AND ARE INCREASINGLY BEING MADE ACCESSIBLE.
VI. CONCLUSION
Access Now, Inc. v. Southwest Airlines, Co., 227 F. Supp. 1312 (S.D. Fl. 2002)
Americans with Disabilities Act, 42 U.S.C. 12181
Workforce Investment Act Amendments of 1998, 29 U.S.C. § 794d
Anne Mulrine, “It’s in the Army Now” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02military.htm
Bank of America, “Accessible Banking,” at http://www.bankofamerica.com/accessiblebanking/
FleetBank, “Accessibility,” at http://www.fleetbank.com/
James M. Pethokoukis, “E-learn and Earn,” in “Special Report: E-learning,” U.S. News and World Report (June 24, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/020624elearning.htm
Rachel Hartigan Shea, “E-learning Today,” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02phoenix.htm
Testimonials for ATAG 1.0 Recommendation, at http://www.w3.org/2000/02/ATAG-Testimonial.html
Testimonials for UAAG 1.0 Recommendation, at http://www.w3.org/2002/12/uaag10-testimonials
Testimonials for WCAG 1.0 Recommendation, at http://www.w3.org/1999/05/WCAG-REC-test.html
Ulrich Boser, “Gaming the System, One Click at a Time,” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02biz.htm
Ulrich Boser, “The Secret Agent,” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02military.htm
World Wide Web Consortium (W3C), "Authoring Tool Accessibility Guidelines 1.0," Recommendation 3-Feb-2000, at http://www.w3.org/WAI/AU/
World Wide Web Consortium (W3C), "User Agent Accessibility Guidelines 1.0," Recommendation 17-Dec-2002, at http://www.w3.org/WAI/UA/
World Wide Web Consortium (W3C), "Web Content Accessibility Guidelines 1.0," Recommendation 5-May-1999, at http://www.w3.org/WAI/GL/
Fed. R. App. P. 29(a)
The World Wide Web Consortium (W3C) is the leading standards organization for the World Wide Web (“Web”), and develops the technologies upon which the Web is based. The Web Accessibility Initiative (WAI), one of four domains (divisions) of the W3C, is the leading international authority on accessibility of the Web.
W3C was created in October 1994 by Tim Berners-Lee, the inventor of the Web, to develop common protocols that promote the evolution and interoperability of the Web. W3C has over 425 Member organizations from around the world and has earned international recognition for its contributions to the growth of the Web. Members are primarily industry and research leaders in the telecommunications, information, and Internet industries. W3C is hosted by the Massachusetts Institute of Technology, Laboratory for Computer Science; the European Research Consortium in Informatics and Mathematics; and Keio University of Japan. W3C has offices in over a dozen countries worldwide that promote adoption of W3C Recommendations and encourage stakeholder participation in W3C efforts.
All parties have consented to the filing of this brief, which W3C files pursuant to Fed. R. App. P. 29(a).
W3C’s interest in this case arises for two reasons. First, W3C files this brief in order to refute the District Court’s erroneous conclusion that no well-defined, generally accepted standards exist for Web site accessibility, and to establish for the record W3C’s authority on Web site accessibility issues. As W3C is the leading standards organization in this area, and as the Web is built upon technical specifications developed by W3C, W3C is exceptionally able to provide the Court with information on Web accessibility standards. Second, W3C writes to clarify certain facts with regard to solutions and approaches for Web accessibility, and with regard to the role of the Web in today’s society. The District Court’s decision reached beyond the scope of the question before it and is based on a misunderstanding of several important facts. While W3C takes no position with regard to the District Court’s holding that a physical, concrete place of public accommodation is necessary in order to state a claim under the Americans with Disabilities Act, 42 U.S.C. 12181 (“ADA”), the W3C believes that such a decision was not necessary to resolve the case at issue and is a direct result of an inadequate factual record. W3C seeks to provide this Court with a fuller understanding of the role of the Web in society, and the importance and feasibility of Web accessibility for people with disabilities.
In dicta, the District Court stated that there appear to be “no well-defined, generally accepted standards” for Web accessibility. Access Now, Inc. v. Southwest Airlines, Co., 227 F. Supp. 1312, 1315, n.1 (S.D. Fl. 2002), (hereafter, “Opinion”). The World Wide Web Consortium (W3C) writes to refute the District Court’s erroneous conclusion on this important point and to assist the Court in understanding the role of the W3C in creating and maintaining these standards. The W3C is one of the ten leading technology standards organizations in the world. It is an accredited organization under the International Telecommunication Union (ITU). The Web is built upon technical specifications developed by W3C.
W3C is responsible for the development of “W3C Recommendations” (technical specifications, understood in the industry as Web standards) that support the growth and utility of the Web. Industry leaders and stakeholders in different technologies come together at W3C with the goal of maintaining the Web as an interoperable and universal information medium. At its core, the Web is a boundless set of information connected through a shared set of common protocols. The Web started with just three common conventions: Hypertext Transfer Protocol (HTTP) (describing how to request and send information), Hypertext Markup Language (HTML) (describing how to assemble information), and Uniform Resource Identifier (URI) (commonly known as URL or Uniform Resource Locator, and describing how to locate information).
As the Web evolved, it grew to include increasingly complex ways to encode and display information. Deploying Web technologies in a non-standard manner undermines the ability of user agents, including browsers and media players, to access and present information in a format accessible and understandable to users; this in turn undermines the role of the Web as a universal information medium. Thus, W3C’s Recommendations play an important role in standardizing the underlying technical protocols and information formats that facilitate access to the wide array of information available on the Web.
W3C has four domains (divisions): Web Architecture, Interaction, Technology and Society, and the Web Accessibility Initiative (WAI). Each area is supported by dedicated W3C staff that coordinates the development of Recommendations and other W3C Technical Reports and deliverables.
A W3C Recommendation is a specification describing a particular technology or protocol. The W3C’s "Recommendation track" is the process used to build consensus around a specification both within W3C and in the Web community as a whole. To become a W3C Recommendation, a proposed standard must pass a series of technical design and implementation hurdles and gain broad support from the W3C membership and other members of the affected communities. Status as an approved W3C Recommendation indicates that W3C Member organizations, including leading consumer organizations and information technology manufacturers, believe that the ideas or technology it contains are appropriate for widespread deployment and promotion.
As a result of W3C’s detailed, consensus-oriented process, W3C Recommendations are valid, stable, referenceable and widely implemented. W3C has produced more than 50 technical specifications which are considered standards in the industry.
While Web technologies continually advance, older specifications produced by W3C and other standard setting organizations are considered stable and are in active use; for example, Extensible Markup Language (XML) 1.0, which pre-dates the Web Content Accessibility Guidelines 1.0, and which is over five years old, is still in use today. W3C Recommendations, like other specifications and standards, are subject to periodic revision. Many standards in use today on the Web were developed in the late 1990’s; while they may have undergone some revision, they remain robust, and have been in continual use—even during the development of new versions. Where newer standards exist they are designed to be backwards-compatible and the older standards are designed to accommodate this compatibility. The District Court’s implied assumption that the WAI guidelines are obsolete because they are “over three years old,” Opinion at 1315, n.1, is simply incorrect.
The District Court also found no indication that the W3C’s Web Accessibility Initiative (WAI) is a generally accepted authority on accessibility guidelines. See Opinion at 1315, n.1. Actually, WAI is the leading authority on Web accessibility in the world. The Web Accessibility Initiative Guidelines, including the W3C Recommendation on Web Content Accessibility Guidelines (WCAG) 1.0, serve as a normative reference either as is, or in derivative works. WAI is supported by W3C’s general membership; in addition it receives funding from the United States government, Department of Education, National Institute on Disability and Rehabilitation Research, the European Commission, and the Government of Canada; as well as organizations including Elisa Communications, IBM Corporation, Microsoft Corporation, SAP, Verizon Foundation, and Wells Fargo. Organizations around the world that have an interest in Web accessibility participate in the development of WAI guidelines and implementation support materials.
WAI’s core mission is to develop guidelines for a comprehensive accessibility solution for the Web. WAI reviews and consults on development of scores of new standards under development at W3C to ensure that they provide the support needed for accessibility. Additionally, WAI facilitates improvement of tools for evaluation and repair of Web sites; develops materials for education and outreach on Web accessibility; and coordinates advanced research and development on Web accessibility.
The District Court misunderstood the nature of the WAI guidelines. The District Court suggested that “no well-defined, generally accepted standards exist” for “programming assistive software and websites so as make them uniformly compatible,” Opinion at 1315, n.1. Yet the complementary set of three WAI guidelines (Web Content, User Agent, and Authoring Tools) do exactly this, addressing the responsibilities of all parts of the accessibility equation, including accessibility requirements for Web sites, as well as the interoperability (compatibility) of assistive technologies with browsers and media players used to access Web sites.
In particular, the Web Content Accessibility Guidelines (WCAG) 1.0, provide common conventions for designers and developers of Web sites to ensure that their Web sites are usable by individuals with disabilities, regardless of the combinations of browsers, media players, and assistive technologies (such as screen readers, screen magnifiers, voice recognition software, etc.,) that may be used by individuals with disabilities.
The WAI guidelines, including the Web Content Accessibility Guidelines (WCAG 1.0), are the normative references for accessible design in the Web industry. WCAG 1.0 has been adopted by the governments of Australia, Canada, the European Union and its Member States, New Zealand, and is used as the basis of the Web provisions in the United States Government's Section 508 rules under the Workforce Investment Act Amendments of 1998, 29 U.S.C. § 794d. Additionally, WCAG 1.0) has been endorsed and adopted by a growing number of corporations.
The WAI guidelines are comprised of complementary W3C Recommendations that establish normative references enabling accessibility of the Web for people with disabilities. Specifically they include:
The Web Content Accessibility Guidelines (WCAG) 1.0 explain what is required for accessible design of Web sites using today's technologies. Some accessibility solutions apply at the level of the information, or “content,” on a Web page. These solutions are consistent with established Web standards. For instance, alternative text for images was required as a part of valid Hypertext Markup Language (HTML) under W3C Recommendations for five years before it was required by the WCAG 1.0. These guidelines were released with the support of industry leaders, as well as support from disability organizations internationally, access research organizations, and governments interested in ensuring that information on the Web is accessible. See Testimonials for WCAG 1.0 Recommendation, at http://www.w3.org/1999/05/WCAG-REC-test.html (last visited March 13, 2003).
The Authoring Tool Accessibility Guidelines (ATAG 1.0) explain what is required for design of software used to build Web sites, so that Web authoring tools automate the production of accessible Web sites and facilitate the repair of inaccessible sites. As more authoring tools conform to ATAG 1.0 and automate more of the production of accessible Web content, Web site designers will be able to produce accessible Web sites with minimal additional effort. These guidelines received international support from industry leaders and organizations, and are currently being implemented by various developers. See Testimonials for ATAG 1.0 Recommendation, at http://www.w3.org/2000/02/ATAG-Testimonial.html (last visited March 13, 2003).
The User Agent Accessibility Guidelines (UAAG) 1.0 explain what is required for accessible design of browsers and multimedia, and for facilitating their interoperability (compatibility) with assistive technologies used by people with disabilities. The conventions in UAAG 1.0 apply at the level of Web browsers (such as Internet Explorer, Netscape Navigator, or Opera) or media players (for example, Real Player, or Windows Media Player), and their interoperability with assistive technologies. For example, the guidelines require that user agent design include full keyboard support for mouse commands, and easily-locatable directions on how to use accessibility features built into browsers. These guidelines also received international support from industry leaders and organizations. See Testimonials for UAAG 1.0 Recommendation, at http://www.w3.org/2002/12/uaag10-testimonials (last visited March 13, 2003).
The District Court found that a “lack of coordination between website programmers and assistive technology manufacturers has created a situation where the ability of a visually impaired individual to access a website depends on the particular assistive software program being used and the particular website being visited.” Opinion at 1315. This misconstrues the relationship between Web sites, browsers and media players, and assistive technologies, implying an obligation for some kind of coordination between the millions of designers and developers of Web sites, and the developers of assistive technologies, rather than an obligation for each to follow the standards established within the Web industry for their particular products or services. It implies that no improvement in accessibility of the Web is possible, or useful, until all aspects of the Web have become completely accessible.
The District Court also noted that “specific information about browser support...changes rapidly.” Opinion at 1315, n.1. Improved implementations of UAAG 1.0 in browsers and media players, and improved interoperability with assistive technologies, will certainly result in overall increased accessibility of the Web. However, improvements in browsers and media players, regardless of how slowly or rapidly these changes occur do not preclude the need for Web site designers and developers to ensure that key accessibility information and accessibility-friendly markup is incorporated into Web sites.
Likewise, while assistive technologies vary in the way they access and display information on Web pages, today’s assistive technologies still require certain information to be present on the Web site. Even improved browsers and assistive technologies cannot make up for the lack of basic accessibility information such as alternative text that was missing from the Southwest site at the time this case was filed.
Recognizing the importance of the Web and the opportunity to build accessibility into its architecture from inception, W3C launched the Web Accessibility Initiative, to develop guidelines and supporting materials for accessibility of the Web.
The Web is information; it is commerce, education, employment opportunity, civic participation, and entertainment. It has more resources than the best research library in the world, and more jobs posted than any employment agency. It fosters civic participation, and promotes government accountability by providing easy access to government information and government officials. The Web has rapidly assumed an essential role in society. To effectively participate in today's information society, meaningful access to the Web is indispensable.
The Web allows individuals to control many aspects of how, when and whether information is presented. The Web is eminently suited to presentation of information, services and products in a non-linear, consumer-directed manner. In addition, hypertext linking allows businesses to provide a range of contextual information difficult to provide in other environments. For example, on a product Web site it is not unusual to find consumer reviews in addition to traditional product details, picture and price. Where the product is information, the document may contain a series of links that direct the consumer to other resources. These features create a flexibility for providing information and services that is unmatched by other methods.
All of these features can be made readily accessible to individuals with diverse disabilities, through implementation of WAI guidelines, when building with Web technologies that have been developed with consideration for accessibility. Individuals with disabilities have a variety of different requirements, yet all of these requirements are supportable by the same set of WAI guidelines. The WAI guidelines seek to enable all users—including individuals with disabilities—to benefit from the rich cultural, civic and commercial offerings on the Web.
Businesses and governments pursue accessible Web design for many reasons. Primary among them are the demographics of the disability marketplace, and the benefits of accessible design in an environment of diverse consumer appliances with equally diverse information presentation needs. With close to 20 per cent of the US population having disabilities, and many of those disabilities affecting access to information— including visual, hearing, physical, and cognitive disabilities, as well as the changing abilities of seniors—companies that forget to design for accessibility inadvertently throw away part of their workforce and a growing share of the marketplace.
Businesses that design for accessibility are also preparing for the future. Along with the evolution of more complex Web technologies, new methods of user access are evolving. The past several years have witnessed a massive expansion in Web access from mobile phones, hand-held devices, and information kiosks. These devices, which pose different constraints on the display and retrieval of information, require many of the same properties as devices that support accessibility.
For many reasons, it is standard practice for consumer oriented businesses and organizations to have a Web site. The Web’s ability to support around-the-clock access to products and services is responsive to an increasingly global marketplace. It provides consumers who have diverse needs and interests with on-demand access, and requires little if any business staff interaction with consumers on a per transaction basis. It supports the provision of information in multiple languages and formats that help overcome barriers to purchasing. As with the telephone before it, the Web has become an essential component of business practice.
Today the Internet, particularly the Web, is a leading engine of the United States economy. In 2002, it is estimated that electronic commerce accounted for $45.6 billion in revenue, an increase of 26.9 percent from 2001. “Retail E-Commerce Sales in Fourth Quarter 2002 Were $14.3 Billion, up 28.2% from Fourth Quarter 2001,” United States Dep’t. of Comm. News (Feb 4, 2003). It would be difficult to find a business listed in the Fortune 500 that does not provide information to the public via a Web site.
Because of the vital role of a Web presence to today’s businesses, coupled with the size of the disability marketplace, many businesses have specifically adopted accessibility principles in order to ensure that their public Web sites and their intranets are accessible to their customers and employees with disabilities. For example, traditional banks and lending institutions provide an array of online services through their Web sites. In fact, the ten largest banks as of year-end 2001 all offered online banking services through their Web sites. See Online Banking Report, “100 Largest Banks (USA)”, available at http://onlinebankingreport.com/resources/100.html (last visited March 13, 2003). The online services offered by banks range from account management, to billing and transferring, to establishing accounts, to borrowing money, and are available at all hours.
Like other retail businesses, banks have been responsive to the needs of their customers with disabilities and some have established explicit policies on Web accessibility. See Bank of America, “Accessible Banking,” at http://www.bankofamerica.com/accessiblebanking/ (last visited March 13, 2003) ("Bank of America is in the process of making our Web site accessible for all users based on priorities one and two of the Web Content Accessibility Guidelines developed by the World Wide Web Consortium (W3C).”). See also FleetBank, “Accessibility,” at http://www.fleetbank.com/ (last visited March 13, 2003) ("In response to the needs of all of our customers, Fleet has developed guidelines for universal web page design, based on the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines 1.0, Recommendation 5-May-1999.").
The Web has also become a mainstay of education. The Web enhances traditional distance education by providing a place for students and faculty to engage in real-time or elapsed-time lectures and discussions, regardless of distance or time constraints. Course materials are provided online, faculty respond to students online; everything from lectures through grading occurs on the Web.
The Web allows educational institutions to reach out over distance and time to provide services to a wide range of individuals. More than 150 institutions offer online undergraduate degrees; more than 200 offer online graduate degrees. See James M. Pethokoukis, “E-learn and Earn,” in “Special Report: E-learning,” U.S. News and World Report (June 24, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/020624elearning.htm. Enrollments in these programs are expected reach 2.2 million by 2004. Id. Enrollment at the University of Phoenix Online alone is close to 50,000. Rachel Hartigan Shea, “E-learning Today,” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02phoenix.htm. Overall, more than 2000 universities offer some “E-learning” courses. See Ulrich Boser, “The Secret Agent,” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02military.htm.
Traditional educational institutions are not alone—companies are training employees online, see Ulrich Boser, “Gaming the System, One Click at a Time,” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02biz.htm, and the United States Army enrolls 31,000 students in its “eArmyU” online classes. Anne Mulrine, “It’s in the Army Now” in “Special Report: E-learning,” U.S. News and World Report (Oct. 28, 2002), available at http://www.usnews.com/usnews/edu/elearning/articles/02military.htm. An increasing number of educational institutions have established Web accessibility policies in order to ensure that this crucial doorway to educational opportunity is available to all including individuals with disabilities.
While W3C takes no position on the District Court's holding that a physical, concrete place of public accommodation is necessary in order to state a claim under the ADA, considering the growing importance of the Web in society and the growing number of people with disabilities in the United States, W3C firmly believes that such a ruling should not be made on summary judgment and in the absence of a well developed factual record.
We hope the court will consider the above points as it proceeds in this case.
Respectfully submitted, ___________________________ |
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Dated: March 17, 2003 |
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CERTIFICATE OF COMPLIANCEI certify that this brief complies with the type-volume limitation of the Rules of the United States Court of Appeals for the Eleventh Circuit. Exclusive of the exempted portions in Rule 32(a)(7)(B)(iii) of the Rules of the United States Court of Appeals for the Eleventh Circuit, the brief contains 3,717 words. |
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Dated: March 17, 2003 |
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CERTIFICATE OF SERVICEI, Nilda F. Andrews, certify and declare as follows: I am over the age of 18 years, not a party to this cause, and employed in the county where the mailing took place. My business address is Center for Clinical Education, University of California at Berkeley School of Law (Boalt Hall), 396 Simon Hall, Berkeley, CA 94720-7200, which is located in Alameda County. On March 17, 2003, I served the following document(s): BRIEF OF THE WORLD WIDE WEB CONSORTIUM SUPPORTING THE APPELLANT by placing a true copy thereof in a sealed envelope and served to each party herein by delivery via Federal Express mail to: |
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K. Renee Schimkat Garth T. Yearick Carlton, Fields, P.A. 4000 Bank of America Tower at International Place 100 SE Second St. Miami, FL 33131 |
Steven R. Reininger Howard R. Behar Rasco Reininger Perez & Esquenazi, PL 283 Catalonia Avenue, Second Floor Coral Gables, FL 33134 |
| Joshua Konecky Goldstein, Demchak, Baller Borgen & Dardarian300 Lakeside Drive, Suite 1000 Oakland, CA 94612 |
Lainey Feingold Law office of Elaine B. Feingold 1524 Scenic Avenue Berkeley, CA 94708 |
Executed this 17th day of March, 2003, at Berkeley, California. |
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Last revised: 3 April 2003 by Shawn Henry, shawn @w3.org
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