A seminal 2012 ruling that confirmed the ADA applies to streaming services, solidifying the legal requirement for captioning on digital-only content platforms.
The National Association of the Deaf (NAD) filed a lawsuit against Netflix in 2010, arguing that the lack of closed captions on the majority of Netflix's streaming content violated the ADA. The plaintiffs asserted that because Netflix was a "place of public accommodation," it had a legal obligation to provide equal access to its services for people who are deaf or hard of hearing.
At the time, Netflix argued that, as an internet-only service without a physical store, it was not covered by the ADA.
The central legal question was whether the ADA applies to purely "virtual" or internet-only businesses that have no physical location open to the public.
The court denied Netflix's motion to dismiss, finding that the ADA **does** apply to services offered exclusively online. Netflix subsequently settled the case.
Netflix agreed to provide closed captions on 100% of its content by 2014, establishing a massive precedent that digital-only streaming services are fully covered by the ADA, significantly impacting the entertainment industry.
STREAMING
IS COVERED
Established digital-only services are subject to ADA compliance.
This case is critical for any organization operating **purely online**. It eliminated the "physical location" defense, making it clear that services like online education, subscription software, and streaming media must fully comply with accessibility requirements, particularly captioning (for video content).