Court Limits Scope of Corporate Deposition in Website Accessibility Lawsuit Against Hyatt

On September 29, 2025, the United States District Court for the Eastern District of California issued an order resolving an informal discovery dispute in an ongoing digital accessibility lawsuit against Hyatt Corporation.

The order follows a telephonic discovery conference held on September 26, 2025, during which all parties agreed to abide by the court's determinations regarding the plaintiff's Federal Rule of Civil Procedure 30(b)(6) deposition notice.

Narrowed Deposition Topics

The court granted in part and denied in part several proposed deposition topics, primarily restricting questioning to defined date ranges and the specific accessibility barriers experienced by the plaintiff on Hyatt's national website:

• Policies, Guidelines, and Planning: The plaintiff may examine Hyatt regarding its policies, procedures, or guidelines concerning website accessibility for visually impaired individuals (Topic 5), as well as its national website accessibility plan (Topic 8), both limited to the period from January 1, 2022, to December 31, 2024.
• Statutory and Technical Compliance: Inquiries into Hyatt's compliance with the Americans with Disabilities Act of 1990 (Topic 7) and with WCAG 2.0 and WCAG 2.1 (Topic 13) were granted in part, limited to the period from January 1, 2022, to December 31, 2024, and restricted strictly to the barriers encountered by the plaintiff.
• Website Design and Complaints: Questions on website design (Topic 11) and third-party complaints received by Hyatt (Topic 21) are similarly limited to January 1, 2022, through December 31, 2024, and to the specific barriers at issue.
• Modifications and Defects: Inquiries regarding website modifications, updates (Topic 23), and specific barriers or defects (Topic 24) were restricted to barriers encountered by the plaintiff, covering the window from January 1, 2022, to August 31, 2025.

Witness Refusal and Excluded Topics

The court also evaluated deposition topics where Hyatt had initially refused to designate a corporate representative:

• Audits, User Testing, and Communications: The court permitted questioning regarding testing, audits, or evaluations (Topic 6), user testing (Topic 14), and non-privileged internal communications (Topic 22) between January 1, 2022, and December 31, 2024, restricted to the barriers the plaintiff encountered.
• Alternative Text: Questioning was permitted regarding text equivalents for non-textual elements (alt-text) and linked images lacking alt-text across the national website from January 1, 2022, to December 31, 2024 (Topic 15).
• Denied Requests: The court completely denied deposition examination on Topics 9, 10, 12, 16, 17, 18, 19, and 20.

Under the order, the plaintiff is required to serve an amended Rule 30(b)(6) deposition notice reflecting the court's limitations.