Court Dismisses ADA Website Accessibility Lawsuit Against Samsung Electronics America Without Prejudice

On July 22, 2025, the United States District Court for the Southern District of Florida granted a motion to dismiss without prejudice in an accessibility lawsuit brought under Title III of the Americans with Disabilities Act (ADA) against Samsung Electronics America, Inc. The ruling held that the complaint did not adequately establish that Samsung Electronics America was the proper defendant tied to the retail store at issue.

Background of the Claim

The plaintiff, a visually impaired individual who uses screen reading software, sought injunctive relief alleging that Samsung Electronics America operates a website that fails to interface properly with assistive technologies. The complaint asserted that the website features an online store locator, thereby creating a nexus to and functioning as an extension of the defendant's physical retail locations. The plaintiff reported multiple unsuccessful attempts to access the defendant's retail stores, specifically identifying a store located at the Dolphin Mall in Florida.

Samsung Electronics America filed a motion to dismiss, citing lack of personal jurisdiction, lack of subject matter jurisdiction, improper venue, and failure to state a claim. In its motion, the company argued that it operates only five "Samsung experience stores" in the United States, none of which are located in Florida or Miami-Dade County, and that it does not own or operate the Dolphin Mall location.

The Court's Analysis

To counter the motion, the plaintiff submitted records from Sunbiz, the official corporation database of the Florida Department of State Division of Corporations, showing that an entity named Samsung Electronics LatinoAmerica Miami maintains offices in Miami. The court noted that Samsung Electronics LatinoAmerica Miami was not named as a defendant, and the complaint included no facts establishing that Samsung Electronics America owns either that corporate entity or the store at the Dolphin Mall.

The plaintiff also raised in a response brief that the defendant operates a Samsung experience store in Sawgrass Mills. While the defendant did not dispute owning stores elsewhere, the court refused to consider this claim because it appeared only in the legal response rather than within the formal complaint.

Under Title III of the ADA (42 U.S.C. §§ 12181–12189), relief is available only against the entity that owns, leases, or operates the place of public accommodation engaged in discrimination. Because the plaintiff did not allege sufficient factual basis that Samsung Electronics America owned or operated the physical location cited, the court concluded that the complaint failed to state a valid claim.

Outcome and Next Steps

The court granted the defendant's motion and dismissed the lawsuit without prejudice. The plaintiff was granted leave to file an amended complaint by August 5, 2025.

Under the court's order, any amended filing must either:

• Present relevant factual allegations demonstrating that the plaintiff attempted to visit a store owned by Samsung Electronics America, or
• Substitute or add the proper corporate entity that owns the store at the Dolphin Mall.

If the plaintiff fails to file an amended complaint by the August 5 deadline, the clerk of the court has been directed to close the case.