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Camacho v. Emerson College

No Jurisdiction Over Massachusetts College Whose Website Is Not Directed at NY Recruits

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OPINION AND ORDER   Emerson College, with its main campus in Boston, Massachusetts, participated in a college fair in Manhattan. Later that same month, it was served with a complaint alleging that a blind New Yorker, Jason Camacho, had attended that fair, gone to Emerson’s website, and run into several web-design-based barriers that prevented him from accessing information through his screen-reader software. Emerson now moves this Court to dismiss Camacho’s amended complaint because the Court does not have personal jurisdiction over it and because Camacho has failed to allege injury sufficient to convey standing. The Court finds that it does not have personal jurisdiction and, on that basis, GRANTS Emerson’s motion.1 I. BACKGROUND Emerson College is a post-secondary school chartered under the laws of the Commonwealth of Massachusetts and with a main campus in Boston. Decl. of Sofiya Cabalquinto (“Cabalquinto Decl.”)

3, 4, Doc. 26. It has no campuses, offices, bank accounts, or other physical presence in New York. Id. 4-10. As part of its recruiting efforts, its admissions team travels the country to visit prospective students. In 2018, the team collectively attended nearly 900 admission events, including 175 college fairs, one of which took place at the Javits Center in New York City in November 2018. Id. 11; Decl. of Camille Bouknight (“Bouknight Decl.”) 3, Doc. 27. Jason Camacho attended that fair, as well. First Amended Compl. (“Compl.”) 33, Doc. 18. Camacho is a blind resident of Brooklyn, New York. Id. 20. He currently attends the Catholic Guild for the Blind and avers that he intends to attend a four-year college to obtain a bachelor’s degree. Decl. of Jason Camacho (“Camacho Decl.”)

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