[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-detail-158927-en":3,"doc-seo-158927-105":30,"detail-sidebar-cat-0-en-105":91},{"code":4,"msg":5,"data":6},0,"success",{"doc_id":7,"user_id":8,"nickname":9,"user_avatar":10,"doc_module":4,"category_id":11,"category_name":12,"doc_title":13,"doc_description":14,"doc_content":15,"file_id":16,"file_url":17,"file_type":18,"file_size":19,"view_count":4,"is_deleted":4,"is_public":20,"is_downloadable":20,"audit_status":20,"page_count":21,"language":22,"language_code":23,"site_id":24,"html_lang":23,"table_of_contents":25,"faqs":26,"seo_title":27,"seo_description":14,"update_tm":28,"read_time":29},158927,687197207639,"Asher","https://ap-avatar.wpscdn.com/davatar_a8503ba1806abce46bf441b54a3ca4cd",7,"Healthcare","Complaint - Ruffa v. Society for Human Resource Mgmt","Complaint alleges that Society for Human Resource Management (SHRM) denies d/Deaf HR professionals and customers equal access to certifications, educational services, and related benefits. The complaint asserts SHRM fails to provide effective communication accommodations such as sign language interpreters, closed captioning, and timely transcripts, and does not adequately disclose accessibility information or how to request accommodations. It further alleges accommodation requests are denied, inadequately offered, or unanswered, resulting in discrimination in violation of Title III of the Americans with Disabilities Act and California civil rights law.","DISABILITY RIGHTS ADVOCATES  \n2001 CENTER STREET, FOURTH FLOOR  \nBERKELEY, CALIFORNIA 94704-1204 (510) 665-8644  \n1  \n2  \n3  \n4  \n5  \n6  \n7  \n8  \n9  \n10  \n11  \n12  \n13  \n14  \n15  \n16  \n17  \n18  \n19  \n20  \n21  \n22  \n23  \n24  \n25  \n26  \n27  \n28  \nREBECCA WILLIFORD – CA BAR NO. 269977 [rwilliford@dralegal.org](rwilliford@dralegal.org)  \nMEREDITH J. WEAVER – CA BAR NO. 299328 [mweaver@dralegal.org](mweaver@dralegal.org)  \nEMILY SEELENFREUND – CA BAR NO. 804482 (Registered Legal Services Attorney) [eseelenfreund@dralegal.org](eseelenfreund@dralegal.org)  \nDisability Rights Advocates 2001 Center Street, 4th Floor Berkeley, California 94704-1204  \nTel: (510) 665-8644  \nFax: (510) 665-8511  \nAttorneys for Plaintiffs  \nUNITED STATES DISTRICT COURT  \nNORTHERN DISTRICT OF CALIFORNIA  \nOAKLAND/SAN FRANCISCO DIVISION  \nTIFFANY RUFFA, KATHRYN CANFIELD, and ISIDORE NIYONGABO, on behalf of themselves and all others similarly situated,  \nPlaintiffs,  \nv.  \nSOCIETY FOR HUMAN RESOURCE MANAGEMENT,  \nDefendant.  \nCase No.  \nCLASS ACTION – Title III of the Americans with Disabilities Act; the Unruh Civil Rights Act  \nINDIVIDUAL ACTION – the Unruh Civil Rights Act  \nDISABILITY RIGHTS ADVOCATES  \n2001 CENTER STREET, FOURTH FLOOR  \nBERKELEY, CALIFORNIA 94704-1204 (510) 665-8644  \n1  \n2  \n3  \n4  \n5  \n6  \n7  \n8  \n9  \n10  \n11  \n12  \n13  \n14  \n15  \n16  \n17  \n18  \n19  \n20  \n21  \n22  \n23  \n24  \n25  \n26  \n27  \n28  \n\n| INTRODUCTION\u003Cbr>1. For years, the Society for Human Resource Management (“SHRM”) has denied Plaintiffs Tiffany Ruffa, Kathryn Canfield, and Isidore Niyongabo (collectively “Plaintiffs”) and other d/Deaf1 human resource (“HR”) professionals equal access to the certifications, educational services, and other benefits it makes available to its members and customers without disabilities. SHRM has failed to provide Plaintiffs and other d/Deaf HR professionals access to sign language interpreters, closed captioning, and timely transcripts of courses and events, as well as other necessary forms of effective communication.\u003Cbr>2. With over 300,000 members in 165 countries, SHRM describes itself as “the foremost expert, convener and thought leader on issues impacting today’s evolving workplaces.”2 SHRM offers widely utilized certifications for HR professionals, which may be obtained through examinations and must be maintained through re-examination or continuing education. For many HR professionals, these certifications are critical for career advancement and skill development. Indeed, SHRM states that over 5,000 employers seek to employ SHRM credential holders each month.3 SHRM also offers courses to help individuals prepare for SHRM certification examinations as well as a variety of other educational programming, most of which individuals can use to earn credits toward SHRM recertification.\u003Cbr>3. SHRM offers in-person as well as online content. Membership is open to the public, and members receive discounts on public-facing content such as exams and courses, as well as access to some members-only programming like podcasts and webcasts.\u003Cbr>4. While SHRM’s “mission is to empower people and workplaces by advancing HR practices and by maximizing human potential,”4 the inaccessibility of its programs denies d/Deaf\u003Cbr>1 The capitalized word “Deaf” refers to a person who is both deaf and identifies as a member of Deaf Culture; a linguistic minority with its own language (signed language) and culture. The lowercase “deaf” refers to the larger group of people with severe-profound hearing loss. Plaintiffs use d/Deaf to encompass the broader group of individuals with severe-profound hearing loss while also recognizing the Deaf identity.\u003Cbr>2 About SHRM, SHRM, [https://www.shrm.org/about-shrm](https://www.shrm.org/about-shrm) (last visited July 19, 2021) .\u003Cbr>3 Why Seek SHRM Certification?, SHRM, [https://www.shrm.org/certification/about/Pages/why](https://www.shrm.org/certification/about/Pages/why)seek-shrm-certification.aspx (last visited July 19, 2021) .\u003Cbr>4 A","cbCaihE11lxZmcfC","https://ap.wps.com/l/cbCaihE11lxZmcfC","pdf",361615,1,25,"English","en",105,"# Introduction\n## Parties and claims\n## Alleged denial of equal access\n## Accessibility accommodations and communication failures","[{\"question\":\"Who are the parties in this complaint?\",\"answer\":\"The plaintiffs are Tiffany Ruffa, Kathryn Canfield, and Isidore Niyongabo, acting on behalf of themselves and others similarly situated. The defendant is the Society for Human Resource Management (SHRM).\"},{\"question\":\"What accessibility accommodations does the complaint allege SHRM fails to provide?\",\"answer\":\"The complaint alleges SHRM fails to provide sign language interpreters, closed captioning, timely transcripts, and other forms of effective communication for d/Deaf participants.\"},{\"question\":\"What laws does the complaint cite as being violated?\",\"answer\":\"The complaint alleges violations of Title III of the Americans with Disabilities Act and California state civil rights law, including claims under the Unruh Civil Rights Act.\"}]","Complaint - Ruffa v. 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