DRAFT — FOR ATTORNEY REVIEW BEFORE SENDING (delete this line and all bracketed placeholders)
Re: Notice of Website Accessibility Barriers and Demand for Remediation — neuins.com
To whom it may concern:
This letter concerns barriers to accessibility on the website neuins.com, operated by Neu Insurance in connection with an insurance office. On the date(s) recorded below, the website was evaluated for conformance with the Web Content Accessibility Guidelines (WCAG) and found to contain the deficiencies described here.
The evaluation followed the W3C Website Accessibility Conformance Evaluation Methodology (WCAG-EM 1.0), using three independent, industry-recognized testing engines (axe-core, HTML_CodeSniffer, and Google Lighthouse) run against the pages as actually rendered in a current web browser. 1 page(s) of the site were evaluated. All evidence was cryptographically sealed at the time of capture (SHA-256 hashing, a Merkle root per page, and a trusted timestamp), so that any later alteration is detectable and the findings are independently reproducible.
The website does not conform to WCAG 2.1 Level AA, WCAG 2.2 Level AA, Section 508. The evaluation identified 2 distinct standards-mapped accessibility failures across 1 WCAG Success Criteria. These are barriers to people who use assistive technology — screen readers, keyboard-only navigation, or magnification. The principal failures:
| WCAG Success Criterion | Instances | Severity | Example evidence file |
|---|---|---|---|
| WCAG 2.4.4 — Link Purpose (In Context) | 2 | serious | page_05_neuins_com/elements/el_1.png |
Automated evaluation detects only a portion of all accessibility requirements; the figures above are a floor, not a ceiling. The "example evidence file" is a preserved screenshot of the failing element within the sealed evidence set (Merkle root e1bfe0aed1e1228c8590a430…).
Title III of the Americans with Disabilities Act, 42 U.S.C. §§ 12181–12189, prohibits discrimination on the
basis of disability in the full and equal enjoyment of the goods and services of a place of public accommodation. Courts
apply WCAG (commonly WCAG 2.1 Level AA) as the practical measure of an accessible website, and recognize claims where the
site has a nexus to the goods and services of the business. This matter is also governed by [CONFIRM the state consumer / civil-rights statute for the entity's jurisdiction].
Note: Entity's state of operation not established; confirm venue and applicable state law.
Within 45 days of this letter, please: (a) remediate the deficiencies so that neuins.com conforms to WCAG 2.1 Level AA; (b) provide written confirmation of the remediation and the steps taken; and (c) adopt a policy and ongoing monitoring to maintain conformance. Because this matter may result in litigation, you are also asked to preserve all electronically stored information relating to the website, including source code, content-management records, and version history, as of the date of this letter.
Nothing in this letter waives any right or remedy, all of which are expressly reserved. The preserved evidence referenced above is available for independent verification. Please direct your response to the sender above by [response date].
Sincerely,
_______________________________
[Sender name]
This document is a template prepared with an automated evaluation tool. It is not legal advice. The recipient's legal name and address, the applicable causes of action, venue, and the sender's standing to assert a claim must be reviewed and confirmed by a licensed attorney before this letter is sent.