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To my (IANAL) nose, this is a good dissection.

The risk with making business decisions around language like "reasonable accomodation" is that the criteria for "reasonable" can change. I'm not an expert in the space, but the watchdogs I read are smelling a change in the wind direction towards increased scrutiny of web accessibility (relevant interest groups are watching the web eat e-commerce and are concerned about what that looks like if the accessibility drum isn't beaten hard early on in the process). Lawsuits like this are expected to increase in 2019.



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