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Honorable Edgardo Ramos United States District Court for the Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, New York 10007-1312

Re: Conner v. Parkwood Entertainment, LLC, Case No. 1:19-cv-00053-ER Dear Judge Ramos: We represent Defendant Parkwood Entertainment, LLC (“Parkwood”) in this case and write on behalf of all parties.

Plaintiff and Parkwood have agreed, subject to the Court’s approval, to extend Parkwood’s deadline to answer, move, or otherwise respond to the Complaint to February 28, 2019 in order to give Parkwood more time to assess the allegations and respond accordingly.

If the Court has any questions, please feel free to contact the parties.

Due to lack of adequate labeling, Plaintiff and blind customers cannot make purchases or inquiries as to Defendant’s merchandise, nor can they enter their personal identification and financial information with confidence and security.

Because of Defendant’s denial of full and equal access to, and enjoyment of, the goods, benefits and services of Beyonce.com, Plaintiff and the class have suffered an injury- in-fact which is concrete and particularized and actual and is a direct result of Defendant’s conduct.

(c) Whether Defendant, through its website, Beyonce.com, denies the full and equal enjoyment of its goods, services, facilities, privileges, advantages, or accommodations to people with visual disabilities in violation of the ADA; and

(d) Whether Defendant, through its website, Beyonce.com, denies the full and equal enjoyment of its goods, services, facilities, privileges, advantages, or accommodations to people with visual disabilities in violation of the law of New York.

Title III of the American with Disabilities Act of 1990, 42 U.S.C. § 12182(a) provides that “No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation by any person who owns, leases (or leases to), or operates a place of public accommodation.” Title III also prohibits an entity from “[u]tilizing standards or criteria or methods of administration that have the effect of discriminating on the basis of disability.” 42 U.S.C. § 12181(b)(2)(D)(I).