Many New York-based businesses with websites, as well as bloggers, vloggers, and other New Yorkers with an online presence, may justifiably feel a bit more immune to lawsuits under the Americans with Disabilities Act (ADA) given the recent decision by the U.S. District Court for the Eastern District of New York in Winegard v. Newsday, No. 19-CV-04420(EK)(RER) (E.D.N.Y. Aug. 16, 2021), holding that a website does not constitute a "place of public accommodation" under the ADA.