National Ass’n of the Deaf v. Netflix (2012)
Background & Claims:
In 2010, the NAD sued Netflix under ADA, alleging that its “Watch Instantly” streaming
service lacked closed captions, discriminating against deaf and hard-of-hearing users.
Court Proceedings & Settlement:
Netflix reached a consent decree in October 2012, agreeing to provide closed captions on all
streaming content by 2014, with timely updates for new releases. The court rejected Netflix’s
argument that it wasn’t a public accommodation because it operates online without a physical
space.
Outcome & Impact:
With $755,000 in fees paid, Netflix set a model for ADA applicability to digital-only
services, reinforcing that “place of public accommodation” can include online platforms.