NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION LAWSUIT

November 01, 2025

IF YOU ARE AN INDIVIDUAL WHO IS BLIND AND/OR HAS A VISUAL DISABILITY, YOUR LEGAL RIGHTS MAY BE AFFECTED. PLEASE READ THIS NOTICE AND THE INSTRUCTIONS CAREFULLY.

This notice is to inform you about the proposed settlement that would resolve the class action lawsuit Douglass v. DK Household Brands Corp., Case No. 2:25-cv-01183 (W.D. Pa.).

The settlement covers all individuals who are blind and/or who have a visual disability who use auxiliary aids and services who have accessed, attempted to access, been deterred from accessing, will access, will attempt to access, or will be deterred from accessing https://www.adhocproducts.com/

, https://coleandmasonusa.com/, https://kenhomwoks.com/, https://swissmarshop.com/, or https://zyliss.com/

The class action lawsuit alleges that DK Household Brands Corp. violated the Americans with Disabilities Act, 42 U.S.C. §§ 12101 et seq., by failing to take the necessary steps to ensure its websites and mobile applications do not discriminate against individuals who are blind and/or who have a visual disability who use auxiliary aids and services to access digital content.

DK Household denies all liability in the case and asserts that its current practices do not violate applicable federal, state, and local law.

The settlement, which must be approved by the Court, would resolve the lawsuit.

DK Household has agreed to ensure its websites and mobile applications meet the success criteria of the Web Content Accessibility Guidelines 2.1 at Levels A and AA, published by the World Wide Web Consortium, available at www.w3.org/TR/WCAG/

, and to follow certain steps to ensure that its websites and mobile applications become and remain accessible.

You have the right to object to the settlement by 02/17/26.

The Court will hold a final hearing to determine whether to approve the settlement on 03/18/26.

Your legal rights are affected whether or not you act. Please read this Notice carefully.

I. WHAT IS THIS LAWSUIT ABOUT?

This case is a class action lawsuit. In a class action, one or more people sue on behalf of others who have similar claims. The person that sues is the class representative. All of the people who have similar claims are part of a “class.” Individual class members do not file lawsuits. Instead, a court resolves all of their claims at once.

This case challenges the accessibility of https://www.adhocproducts.com/

, https://coleandmasonusa.com/, https://kenhomwoks.com/, https://swissmarshop.com/, and https://zyliss.com/

. Plaintiff alleged that these websites were not accessible to persons with vision disabilities and that this violated the Americans with Disabilities Act. Plaintiff sought an order requiring DK Household to make its online content accessible.

II. WHO DOES THIS SETTLEMENT AFFECT?

This settlement covers all individuals who are blind and/or who have a visual disability who use auxiliary aids and services to navigate digital content and who have accessed, attempted to access, or been deterred from accessing these websites from the United States.

III. WHAT DOES THE SETTLEMENT PROVIDE?

A. DK Household Will Make Its Digital Properties Accessible.

DK Household agrees to take steps to make its websites, mobile applications, and any new digital properties accessible to individuals who are blind and/or who have a visual disability and who use auxiliary aids and services. DK Household will ensure these digital properties meet WCAG 2.1 Level A and AA standards.

B. DK Household Will Institute Accessibility Procedures.

DK Household will implement procedures to ensure its digital properties become and remain accessible. These steps include:

Requesting vendors of third-party content to provide content in a format that conforms to WCAG 2.1 or can be made to conform.
Designating an Accessibility Coordination Team responsible for ensuring accessibility and resolving accessibility-related inquiries.
Retaining an Accessibility Consultant knowledgeable in ADA and WCAG to assist with audits, advise on accessibility improvements, verify compliance, and issue accessibility letters.
Completing an initial accessibility audit of all websites listed above, using professional and appropriate testing processes.
Developing and implementing an accessibility strategy to ensure ongoing accessibility.
Displaying a link to an accessibility statement prominently at the beginning of the user experience so that individuals using assistive technologies become aware of available resources.
Training all employees involved in digital design, development, or maintenance on WCAG 2.1 Level A/AA requirements.
Training customer service personnel to assist individuals with disabilities who encounter difficulties using the digital properties.
Updating bug-fix policies and procedures to ensure accessibility barriers are addressed.
Providing support during business hours for individuals encountering accessibility issues.

C. DK Household Will Create a Dispute Resolution Procedure.

DK Household will forward all accessibility-related complaints to Class Counsel, who will work with DK Household to ensure the issue is resolved in accordance with the settlement.

D. DK Household Will Pay Attorneys’ Fees and Costs.

The named plaintiff will receive a $2,500 incentive award, subject to court approval.

Class Counsel may seek attorneys’ fees and costs up to $59,000 for work performed before DK Household’s initial accessibility deadline, plus up to $15,000 for each additional year if more time is needed. The Court must approve the fee award. The motion for fees will be available at https://www.dkhouseholdadasettlement.com

within seven days of filing.

IV. DOES THE SETTLEMENT AFFECT MY LEGAL RIGHTS?

If approved, all class members will be bound by the settlement’s terms regarding accessibility and will release all claims for injunctive relief related to alleged discrimination regarding digital accessibility that arose before the settlement becomes effective. Class members other than the named plaintiff retain the right to pursue monetary claims.

V. CAN I OBJECT TO THE SETTLEMENT?

Yes. To object, you must submit a written objection on or before 02/17/26. Your objection must:

a) Clearly identify the case name and number: Douglass v. DK Household Brands Corp., Case No. 2:25-cv-01183 (W.D. Pa.)
b) Be mailed to the Clerk of Court for the U.S. District Court for the Western District of Pennsylvania, 700 Grant Street, Courtroom 9B, Pittsburgh, PA 15219, or filed in person at any courthouse location
c) Be received by 02/17/26

If you wish to speak at the fairness hearing, you must say so in your written objection. If you are represented by a lawyer at the hearing, you are responsible for paying your attorney.

VI. DO I HAVE A LAWYER IN THIS CASE?

Yes. The Court has appointed Kevin Tucker, Kevin Abramowicz, Stephanie Moore, Chandler Steiger, Kayla Conahan, and Jessica Liu of East End Trial Group LLC as Class Counsel. Their contact information is listed below.

You do not need to pay Class Counsel. DK Household will pay attorneys’ fees and costs in an amount approved by the Court.

VII. WHEN AND WHERE WILL THE COURT APPROVE THE SETTLEMENT?

The Court will hold a hearing on 03/18/26 to determine whether the settlement is fair, reasonable, and adequate. You are not required to attend.

VIII. HOW DO I GET MORE INFORMATION?

This notice summarizes the proposed settlement. For full terms, please review the settlement agreement at https://www.dkhouseholdadasettlement.com

, contact Class Counsel, access the court docket via PACER at https://ecf.pawd.uscourts.gov

, or visit the Clerk of Court’s office (address above) during business hours.

To obtain this notice in alternate formats, contact Class Counsel.

IX. CONTACT INFORMATION

Do not contact the Court or defense counsel with questions.

Class Counsel:

Kevin Tucker
Kevin Abramowicz
Stephanie Moore
Chandler Steiger
Kayla Conahan
Jessica Liu
East End Trial Group LLC
6901 Lynn Way, Suite 503
Pittsburgh, PA 15208

Emails:
ktucker@eastendtrialgroup.com

kabramowicz@eastendtrialgroup.com
smoore@eastendtrialgroup.com
csteiger@eastendtrialgroup.com
kconahan@eastendtrialgroup.com
jliu@eastendtrialgroup.com

Phone: (412) 877-5220
Website: https://eastendtrialgroup.com/