22nd Annual Accessing Higher Ground: Nov 18-22, 2019



Practical Strategies for Meeting Accessibility Laws in Higher EducationPresented by Ken Nakata (HiSoftware) at Accessing Higher GroundNovember 15, 2012This is a rough transcript created in preparation for the final presentation. The live presentation varied somewhat from this transcript and included responses to questions posed by the audience-- the substantive content and key messages, however, are the same. It is provided here as a courtesy because the slides are illustrative only, contain substantial animations, and do not convey the content of the presentation.Good afternoon. My name is Ken Nakata and I and the Director of the Accessibility Consulting Practice at HiSoftware. Our tools are one of the most powerful and commonly used tools for website accessibility and has hundreds of customers among colleges and universities. I work, however, on the other side of the house where I work with clients on manual testing and as a consultant in more gray areas combining law and technology. Being a consultant, I am fortunate that I get to work with hundreds of clients, both public and private and large and small. This gives me the opportunity to see how different organizations handle accessibility – as well as gain some insight into which methods work better than others.Before I came to HiSoftware, I worked for 12 years as a Senior Trial Attorney in the Disability Rights Section of the US Department of Justice and I am probably best known for the work that I did during the second half of my career at Justice working on Section 508 of the Rehabilitation Act. I started at Justice immediately after the ADA went into effect and spent six years working on traditional accessibility cases. During the second half of my career at Justice, I started working on Section 508 and helped write the Section 508 standards issued by the Access Board. In fact, I helped write the "guide" to web accessibility with Doug Wakefield (from the Access Board) and Don Barrett (from the Department of Education) that is currently on the Access Board site. Within the federal government, I'm best known for my work in the intra-agency Section 508 Working Group and for conducting three of the government-wide surveys of information technology (and related reports to the President and Congress on Section 508 implementation).Today, I have two goals in my presentation. My first goal is to give you a high-level overview of different accessibility laws – and how they have played out in recent litigation and settlement agreements. Based on this, I would like to give you some specific strategies or ideas that you can take to the policy level when you are implementing accessibility within your organization.We'll start today's presentation looking at how accessibility laws have evolved – and how these older laws apply to today's technology. After all, Section 508 is 14 years old, the ADA is 22 years old, and Section 504 is 39 years old. Nevertheless, each of these laws have been involved in the most recent of settlement agreements!Next, we'll review some of the recent accessibility complaints and analyze how some of the general principles in these older laws have been shaped to meet today's technology. Lastly, I like to share with you my perspective as a consultant in working with clients about ways that this can be done better, cheaper, and more efficiently. Finally, I'd like to close with some thoughts on some trends that I've seen in PDF remediation.If we look back to the beginning of disability rights laws, we would have to go back to shortly afterward World War I to the Smith-Sears Act. This law was intended to provide rehabilitation opportunities for soldiers injured during World War I. Like many of the earliest disability rights laws, the focus here was on "rehabilitation" rather than "civil rights".Disability rights laws had a very slow beginning as over 50 years passed before the next major disability rights legislation. Next, in 1964, Congress passed the Civil Rights Act. While not a disability rights law, it was instrumental in shaping the civil rights movement and Title III of the ADA wouldn't have been possible without it.Nine years later, Congress passed the Rehabilitation Act of 1973, which included Section 504. This law prohibited discrimination against people with disabilities by federal agencies and federal fund recipients.Over the next 20 years, federal courts used Section 504 to develop many of the essential principles that we now find in Title II of the ADA.Finally, in 1990, Congress passed the Americans with Disabilities Act. This law is clearly the most important law for people with disabilities around the world and it is instrumental in shaping the basic rights that are a foundation of modern disability rights. As I mentioned before, the ADA wouldn't have been possible without the Rehabilitation Act of 1973 and the Civil Rights Act of 1964.(…continued)Next, in 1996, Congress passed Section 255 of the Telecommunications Act. While this law doesn't apply directly to colleges and universities, it affects most of the telecommunication technologies that we rely on.Two years later, Congress amended Section 508 of the Rehabilitation Act. While there was an earlier version of Section 508 (passed in 1986), the newly amended version authorized – for the first time—specific IT standards and lawsuits against federal agencies if they procured inaccessible technology. While Section 508 does not directly apply to anyone other than the federal government, it is probably the most influential technology-related accessibility law and has been widely adopted at the state and international level. By requiring the government to only buy accessible technology, it reshaped market forces to encourage accessibility and made it highly desirable for companies to innovate in the area of accessibility.Most recently, in 2010 Congress passed the 21st Century Communication and Video Accessibility Act or “CVAA”. I had the privilege of testifying before Congress on an earlier version of this law that was being debated. Like Section 255, it does not apply directly to colleges and universities, but it will apply to their technologies. Over time, technologies such as web-based conferencing and instant messenger chat applications will become increasingly accessible because of this important law.Because the passage of the ADA was so important, most of us think that the modern era of accessibility as only been within the last 22 years. If we look at this period a little bit more closely and with a little bit more granularity, we will notice that progress in information technology accessibility sped up at an exponential rate during this time. Beginning with the passage of the ADA in 1990, a relative lull took place until the Section 508 amendments in 1998, which I mentioned before. Then, in 1999, the Web Accessibility Initiative (or “WAI”) issued version 1.0 of the Web Content Accessibility Guidelines (or “WCAG”). The next year, the Access Board issued their final Section 508 standards. Only six years later, the Access Board started the process of refreshing these standards by forming the TEITAC, which issued its final report in 2008. That same year, WAI issued WCAG 2.0. Two years later, the Access Board issued its first ANPRM for refreshing the Section 255 and 508 accessibility standards. This was only six years after the first Section 508 standards were created. Later that same year, on the 20th anniversary of the ADA, the Department of Justice issued its first ANPRM to consider augmenting Title II and III of the ADA to include websites and – for the first time – officially considered adopting specific web accessibility standards to these entities.The second half of this period has also seen increased litigation and complaints involving inaccessible technology. All of the complaints involving inaccessible technology that we will discuss today have been since 2000 – and most of the complaints of interest have occurred since 2010.Looking back to our overall timeline of accessibility laws, it becomes clear that most of the activity that we are interested and has only taken place within the very recent past.This highlights three points that I would like to focus on today:First, most of the laws that were talking about were developed many years ago – well before their authors could ever have imagined today's technologies.Second, I hope to show how well these older laws applied to even the latest technologies.Finally, I hope to show that this means that there are relatively few surprises – and that by understanding how these laws operate, you can take the necessary steps to avoid trouble in the future.I think that this is important because I’ve seen plenty of cases where organizations get hung up in the details of the specific provisions and regulations in disability rights laws—and lose sight of the larger picture that really forms the basis of most complaints. For instance, Section 504 and Title II have elaborate requirements of grievance procedures or designation of an agency official that seem unusual and above-and-beyond simple non-discrimination, but almost invariably, that’s not what starts a complaint. Instead, what starts a complaint is an allegation that goes to the core of what these laws were designed to prevent—and the other violations only become evident as the case unfolds. Ultimately, settlement agreements tend to reduce everything to the same level—and it is easy to think that they are all equally important. Staying out of trouble means both knowing all of the technical requirements but placing special emphasis on knowing what’s really at the core of these laws and how they work at a high level. Before we can begin to discuss the most recent lawsuits and litigation, we need to have a basic and common understanding of how these essential laws operate. This presentation is only a survey of the highlights – a proper examination would require an entire semester in law school.First, there is Title II of the ADA and Section 504 of the Rehabilitation Act. Title II applies to state and local governments, while Section 504 applies to federal agencies and federal fund recipients. Congress made clear (in the Civil Rights Restoration Act of 1988, which overturned the Supreme Court decision in Grove City College v. Bell) that the breadth of Section 504 was to be extremely broad in the education setting. Thus, if the physics department of a private university received a grant or any federal financial assistance, the English department would also be covered. Thus, for all practical purposes, this set of laws applies to all colleges and universities. Both of these laws essentially require the same thing: "program access," which means that all programs, services, and activities must be accessible "when viewed in its entirety". The Fifth Circuit case of Martin v. MARTA is a good example of what this means in the context of webpages. MARTA is the Metropolitan the Atlanta Regional Transportation Authority and it provides regional transportation services in the Atlanta area. They provide bus, train, and paratransit scheduling information through their websites, printed brochures (braille upon request), and telephone lines. Disability advocates sued MARTA, claiming that this information was inaccessible. After lengthy discovery, the court concluded that the agency didn't answer their telephones, only provided out-of-date braille schedules, and maintained an inaccessible website – and ordered that MARTA correct these violations.While Martin v. MARTA is often cited by advocates for the claim that state and local government websites must be accessible, this is an overstatement. Instead, the court said that Title II (and similarly Section 504) requires that the overall "program" must be accessible. Thus, if MARTA promptly answered its telephones and provided braille schedules that were current, it may not have been required to make its websites accessible. Under Title II and Section 504, whether program access is truly achieved is a very case-by-case determination – and both the Department of Justice and the Department of Education have indicated that "program access" is a much stricter standard in the educational context. Shortly before I left the Justice Department, I wrote a brief white paper which you can find on the Department of Justice website on the obligation of state and local governments in the area of website accessibility—and it highlights that educational institutions have higher obligations with regard to 24/7 accessibility.(…continued)As I mentioned before, the Justice Department is considering the possibility of accessibility standards under the ADA. Because most settlement agreements include some requirement to adopt accessibility standards (currently WCAG 2.0 level AA), the "de facto" standard for Title II and Section 504 is WCAG 2.0 level AA. While WCAG 2.0 AA certainly is not the “official” standard, it is the bar that you would have to settle at (if you were sued).As far as exemplary cases are concerned, I’ve described Martin v. MARTA in some detail. Another exemplary case in this context is the Penn State litigation, which we will talk about later.The next important law is Title III of the ADA. This law applies only to the private sector and, for that fact, owes its existence to the 1964 Civil Rights Act.I like to think of Title III as having two different types of requirements.One set of requirements are the highly specific and prescriptive architectural standards that apply to new construction and alterations. These requirements are universal design requirements that apply in the absence of having a particular instance of discrimination against anyone.The second type of requirements are more general nondiscrimination requirements, such as the requirements to make reasonable modifications in policies or to provide effective communication. Most of the time—but not always—cases in this second category require a case-by-case determination.Very roughly speaking, complaints involving inaccessible web sites have fallen into the second category because the ADA regulations do not include specific standards for web sites like they do for architecture. As I mentioned before, the Department of Justice is considering the adoption of specific accessibility standards to Title III. In addition, settlements are also making WCAG 2.0 level AA the de facto standard here as well.(…continued)Of course, the most famous of the settlements involves the NFB v. Target litigation, in which Target Corporation agreed to pay $6 million in damages. Two points are important with regard to Target that I would be remiss in not mentioning.First, Target is a perfect example of a settlement that set the bar effectively at WCAG 2.0 level AA. Since then, every settlement agreement by any disability rights group has used this standard. Again, nothing in the regulations currently says you must use WCAG 2.0 AA—but if you get sued, you should expect that the other side won’t let you off the hook unless you do.Second, Target Corporation paid $6 million because of the California Unruh Act – and not because of Title III. Target Corporation settled because this law authorized $4,000 per claim and, for $6 million, Target Corporation agreed to pay up to $3,500 per claim. In this regard, Target Corporation should be seen as a warning sign to any business entity (potentially including any private college or university) serving residents in California – what happened to Target could easily happen elsewhere. Having said that, I think that it is very unlikely that any college or university is going to be the next “target” for a lawsuit under Unruh—but we likewise shouldn’t ignore that Unruh is a factor lurking out there.Another example of Title III in action is the Princeton University settlement involving Kindle devices, which we will talk about later.The last set of laws are Section 508 and Section 508-like laws and policies. I mentioned before that Section 508 strictly applies only to federal agencies. It does not apply to states or federal fund recipients. However, many state and local governments have adopted their own Section 508-like law and many other public entities (including public colleges and universities) have adopted their own Section 508-like policy for their organizations. The key concept in all of these laws and policies is their use of specific standards for IT procurement and development. As I mentioned before, the Access Board is moving towards much more stringent standards – and ultimately harmonization to WCAG 2.0 level AA.So with this basic understanding of accessibility laws behind us, the next question is how do these laws work in litigation and settlement agreements? In preparing for today's presentation, I used a great compilation of accessibility-related litigation and settlement agreements compiled by Karl Groves of Massachusetts. As shown on the screen (in very small print) a large number of colleges and universities have been sued and "made the news." In addition, an even larger number of private businesses and not-for-profit entities have also been sued. State and local governments have been affected and even the federal government including the Department of Education) have been targeted by disability rights organizations. Not to be outdone, the Government of Canada has also been sued under Canadian law. Don’t worry if you can’t read each line of the screen—the listing isn’t intended to give you details as much as to just give you a sense of the overwhelming number of cases! The specifics (including links to each case) are available on Karl’s website at .Much more interesting than "who" was sued is "why" they were sued. In preparing for today, I examined each of these cases to see what was alleged or litigated and included in any settlement agreements and came across some interesting trends. Among these 53 cases are settlement agreements: 41 complaints involved web accessibility,8 involved in accessible kiosks, ATMs, or point-of-sale machines,6 involved e-readers or Kindle devices,4 involved a "comprehensive review" stemming from web in accessibility, and2 involved inaccessible software.In case you're wondering why those numbers add up to more than 53, it is because some of these settlement agreements or cases fall into more than one category. As I examined each of these cases and settlement agreements, I found that, within each of these five categories, the complaints were very similar in their factual scenarios and allegations and also in the final resolution. While we don't have time to review each case, we do have time to briefly review each category to try to understand why each case happened—and how to avoid them at our institutions.The most common type of complaint involved inaccessible websites. While the complaints against NYU, Northwestern University, and Florida State University are typical, there are many others (and many more yet to come) that involve this type of complaint. The typical fact scenario is that a university or college relies on a web-based content management system (such as Blackboard) or a collaboration technology (such as Google Docs) that is claimed to be inaccessible by a student with this disability or a disability rights organization. This raises potential problems under Title II and Section 504 because the inaccessible technology is effectively a gateway to the educational program – and thus program access is violated. In the context of Title III, an inaccessible CMS or collaboration technology violates the "effective communication" requirement and also has the effect of segregating students with disabilities – both of which are prohibited under Title III. In this type of cases, the typical resolution is that the University must refrain from using an inaccessible content management system or collaboration technology. The settlement agreements usually go further and specifies that all web content at the college or university must comply with WCAG 2.0 level AA. In a few rare instances, colleges or universities must also pay damages and/or attorney fees as part of the settlement agreement.The second type of case involves an inaccessible kiosk, ATM, or point-of-sale machine. The CVS and JetBlue Airways settlement agreements are good recent examples of this type of case. In this type of case, a company typically installs a point-of-sale machine that may rely on a touchscreen or a kiosk or an ATM that fails to have a voice output. As a consequence, a user with a disability must rely on third parties to operate the machine and loses privacy when entering PIN information. These scenarios create obvious problems under Title II and Section 504 because the overall "program" is inaccessible to people with disabilities because opportunities as a whole must be "readily accessible to and usable by individuals with disabilities." Title III of the ADA is also violated because it is a denial of the equivalent benefits and opportunities to customers with disabilities. Because the ADA Accessibility Guidelines also include design standards specific to ATMs, the architectural standards of the ADA are also sometimes at issue. In all of these settlement agreements, the entity must replace the kiosk, ATM, or point-of-sale machines with accessible versions.Of particular interest to colleges and universities recently are complaints involving Kindle or eReader devices. The recent Princeton University settlement agreement is typical of this type of case. These complaints involve universities that adopt eReader devices (such as the Amazon Kindle) as a means of providing text for students. Title II and Section 504 are both at issue because of the University's encouragement and reliance upon these devices. In the case of Princeton University, Title III is also at issue because of the denial of equivalent benefits and lack of effective communication for students with disabilities. In all of these settlement agreements, the resolution is always the same. Universities must refrain from using inaccessible eReader devices unless it can provide an accessible alternate reader that offers the same information, interactions, services, and ease-of-use as the inaccessible devices. When looking at these cases and settlement agreements, it is important to remember that students are not prohibited from using these devices. The fact that the University adopts or encourages the use of inaccessible devices as an integral part of an educational program (thus affording nondisabled students with a significant advantage) is the key fact that raises potential liability.Next are the "comprehensive review" cases. In many respects, I think that these are the "website complaint of the future." The Penn State settlement agreement is typical of this type of case. However, it's important to remember that these are not entirely novel cases – the Department of Justice has been entering into similar (in fact broader!) settlement agreements under its Project Civic Access (or “PCA”) program for years. Personally, I also have been performing this kind of review for NASA as part of its Section 504 reviews and more recently for the City of Chicago under Title II of the ADA.In the educational context, the typical fact scenario is that a disability rights group files a complaint with either the Department of Education or the Department of Justice that initially starts with a complaint involving an inaccessible website. As the investigation "evolves", it grows into a campus-wide comprehensive review of IT accessibility. Ultimately, the college or university agrees to terms much broader than the initial complaint and commits to a campus-wide review of all technologies that may impact on people with disabilities, including fixing all of its webpages (to WCAG 2.0 level AA) as well as ensuring that all ATM's and kiosks are also accessible. The university must also agree to a strong policy statement for accessibility as well as thorough and regular refresher training for all IT professionals. Lastly, the universities must agree to purchase only accessible technology to ensure that future IT is accessible to students with disabilities.These cases demonstrate the breadth of the "program access" requirement under Title II and Section 504. As novel as these cases may same, they shouldn't come as a major surprise to colleges and universities, which have been subject to Section 504 and Title II for decades (both of which require comprehensive self-evaluations and transition plans).The last of our five types of IT complaints and settlement agreements involve software complaints. A typical case in this category is the employment complaint made against the State of Texas. In these types of cases, an organization purchases a large enterprise software that is inaccessible to people with disabilities. As a consequence, employees with disabilities can't do their jobs and file an employment complaint. Unlike any of the categories that we talked about before, these are employment complaints and the involve the failure to provide reasonable accommodations to employees. In addition, Section 508 is frequently violated if the entity has a law or policy similar to Section 508. In these types of cases, the organization usually commits to upgrading to an accessible version of the software at the next revision cycle – or replacing it with an accessible competitive product. The organization typically agrees to only buy accessible technology in the future and to pay attorneys fees and/or compensatory damages. Obviously, attorneys fees and damages, however, are frequently not the scary part of this kind of lawsuit—it’s the cost of replacing or changing enterprise software.-114300-1149350Having reviewed the laws and typical cases involving inaccessible IT, we can come to some conclusions about how to avoid trouble in the first place.First, if there is a publicly available and commonly used accessibility standard for the technology, use it!. For instance, websites should all follow WCAG 2.0 level AA and software should be designed to common accessibility APIs if they are available. This is important because settlement agreements almost invariably set the bar at WCAG 2.0 level AA and migrating your organization to this standard effectively insulate yourself from this kind of litigation. Similarly, with the availability of PDF/UA, organizations have a baseline standard that they should focus their PDF remediation efforts on.Second, while automated solutions are great for rapidly scanning the overall accessibility of web content, never forget about the importance of manual testing.Third, it is probably a good idea to perform a comprehensive review of all of your information technology – and its impact on all users with disabilities. This is important because it affords your organization the opportunity to understand which technologies are inaccessible – and what the fallbacks are for students with disabilities (which is key to program access).(…continued)To avoid future problems, it is important to include accessibility in any IT approval process for both development and procurement. This is a basic step that the federal government has advocated for years and is essential to Section 508's success.Lastly, it is highly useful to consider the entire lifecycle of IT development. At HiSoftware, I worked with a major brands company that maintained over 2,500 separate websites globally (and each site was refreshed every two years). As part of a site "refresh", the company would have a design company create its wireframe and graphics and then have a separate development company implement their designs. For instance, modal dialogs are really hard to make accessible, so if designers avoided them in the wireframe stage, developers wouldn’t have to struggle to find an elaborate ARIA-type of solution in development. An even simpler example are drop-down “select” elements—which designers have automatically trigger when the user selects an element in a list. At the wireframe stage, we can encourage them to place a button next to the control to activate it. Doing so means that the developer implementing that wireframe will be much less likely to use an onChange() JavaScript event handler, which is notoriously hard for screen readers to us. Instead, the developer will simply know that the button activates the control—and accessibility will be much more automatic. By helping them identify common accessibility problems that could be caught in the design phase, we help the company avoid a huge number of headaches later in the development process.All of these ideas are common sense and none of them are very radical –by applying common sense and a basic understanding of accessibility laws, it is fairly easy to stay out of trouble.As I mentioned before, I'm a consultant who works with many different clients. This has afforded me an opportunity to see things that work and things that don't work. I would like to share with you for a few minutes what I consider the future of IT governance: good requirements definition and management. Unfortunately most organizations pay lip service to this idea or think that they have it mastered. Out of the hundreds of clients I have worked with over the years, less than half a dozen clients do it well and I can only identify one that did it superbly well. Furthermore, it doesn’t take elaborate tools to do it well. In fact, the one client that I mentioned that did it better than anyone else, managed it all for a one of largest Federal agencies with nothing more than an Excel spreadsheet!As an accessibility professional, you undoubtedly have competing stakeholders in areas such as privacy and security. In addition, each of you is competing for the attention of end-users (in this case faculty developing content, web developers, programmers, etc.). This scenario creates competition and confusion. As stakeholders compete, one voice usually wins the larger budgets to the exclusion of the others (and it usually isn't accessibility that wins). Also, the same message may not be repeated consistently across the organization – and even more likely it won't be heard consistently. Marketing your efforts and gathering attention of takes time away from your real goal: accessibility compliance and the entire organization suffersIf you need a message to go along with this, think of it as the opposite of the popular Lending Tree advertisement. The motto in that ad is “when banks compete you win.” The motto here is “when stakeholders compete, everyone loses.”An alternate strategy is to entirely separate the requirements process from the stakeholders. As I mentioned before, many organizations think that they do requirements definition and management well, but in my experience less than half a dozen of the most savvy organizations do it effectively. Most surprisingly, it often has little to do with budget or size.Starting with the same essential group of stakeholders, these organizations have a discipline-agnostic requirements manager who effectively sets up a database (which can be as simple as an Excel spreadsheet) that consolidates requirements from all stakeholders. In this model, anyone can be a stakeholder and establish requirements – and they are treated equally.Consolidated requirements are then reviewed by all stakeholders to ensure that they do not conflict with their specific area of domain expertise. The requirements are managed centrally by the requirements manager, who also creates a "requirements allocation questionnaire". This document asks a series of questions that identifies which requirements are at issue for each project. For instance, a good requirements allocation questionnaire may ask if the project may ever involve multimedia content (if not, then the captioning requirements would not be allocated).As users develop projects or content, they use the requirements allocation questionnaire to obtain the specific subset of requirements specifically pertinent to their project. This ultimately reduces user frustration because an entire set of inapplicable requirements is not simply "thrown over the fence" at them. This means that requirements are taken much more seriously and ultimately met. The advantages of this model are that it enables stakeholders to collaborate instead of compete – thus freeing them to focus their resources on truly important problems. It also yields perfect consistency and highly specific requirements for the users. This garners respect and a high level of compliance because only a single requirements management system needs to be met before a product ships or content goes live.As I mentioned, we have helped organization shape their accessibility requirements and develop sound requirements definition and management practices – and I truly believe it is the future for everyone.NASA really perfected this work early on in their space program. It is really an amazing feat of organizational brilliance that NASA was able to send a man to the moon almost 40 years ago when we consider now that these were immense, untested projects using hundreds of contractors selected through a “lowest cost bidder” process. Nevertheless, these projects had to work perfectly the first time and had human lives on the line. An approachable resource here is the works of Ivy Hooks, a noted requirements consultant. While the stakes are somewhat less dire, software development is another area where requirements definition and management have been refined—and a good resource in this area is the works of Karl Wiegers.I like to finish with some thoughts – or observations – on PDF processes that I’ve noticed.The first process is one which is becoming popular in the private sector. In this model, content creators are encouraged to create accessible PDFs but might not get it right. Original documents all have a special tag that is only rendered to screen reader users. When a screen reader user cannot access the document, it provides instructions and an accessible version is provided within a very short compressed timeframe. The new document is provided to the end-user and replaces the original document on the website.A second relatively new PDF accessibility process involves a simple tag (that includes attributes providing accountability for accessibility such as the content creator, date of creation, level of accessibility, etc.). All new accessible PDFs are deployed to the website. The organization then uses an automated scanning solution (such as HiSoftware's Compliance Sheriff) to scan the PDFs for this metadata. This process enables PDFs without this metadata to be targeted for remediation. At the same time, users with disabilities may be accessing the site and request that other documents be corrected. These user-requested documents are given priority in the overall process of remediating older inaccessible PDFs. As these documents are corrected, they replace the older versions and include the same metadata for accessibility.Both of these solutions (and hybrid solutions that utilize both approaches) have their own specific benefits and enable organizations to finally wrap an intelligent process around the thorny problem of having thousands (or millions) of inaccessible PDFs.I hope this presentation has given you some new ways of looking at an old problem – or some old ways of looking at a new problem. Either way, I hope that IT accessibility makes a little bit more sense and is a bit more predictable from a legal perspective. If you would like to contact me, I can be reached at k.nakata@ Thank you for your attention and I hope to see you soon. ................
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