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This case arises out of Target’s policy and practice of denying the blind access to Target.com, including the goods and services offered by Target stores through Target.com. Due to Target’s failure and refusal to remove access barriers to Target.com, blind individuals have been and are being denied equal access to Target stores, as well as to the numerous goods, services and benefits offered to the public through Target.com

First Amended Complaint, Article 24, National Federation of the Blind, et al versus Target Corporation

The point made above, from the accessibility lawsuit against Target corporation by Bruce Sexton and the National Federation for the Blind, is that Target has explicitly denied the blind access to their resources through their refusal to remove barriers to access. This is somewhat semantically different than the terminology commonly used within the accessible web development world. The common language in web development is to state that you are "adding accessibility features" to a website – I’ve certainly used this construction myself. However, it may be far more accurate to state that my actions as an accessible developer are not to "add features" but to remove barriers.

A website, in it’s simplest form, could be considered nothing more than an unorganized collection of hyperlinks and text. It is nothing but information. A web designer transforms this into a website by adding organization, images, color, and sometimes multimedia to this otherwise plaintext collection of information. In this process, it is easy to add numerous barriers to access. Unwary developers may provide an organization which is visually exciting but when read in a linearized fashion makes little sense. They may use color contrasts which are only barely visible (or not visible) to users with poor vision. Any number of problems can arise during the design of a site which a designer unversed in accessibility may be completely unaware of.

An accessible web developer’s job is to remove barriers to access, if working on an existing site, or to minimize the barriers they create when designing an original site. It is almost impossible to create a site without introducing some form of barrier – at the very least, the linearization of text will require that elements come in some order – and any order will be a barrier to the person who wants to reach a different section of the page. However, an accessible web developer can also create aids to the disabled web user. Where a barrier must be erected, an aid must be created. In the previous situation, skiplinks should be provided, which will allow the user to jump between navigation, content, and any other necessary sections of the page.

A lack of accessibility is not inherent to web design. If a site is not accessible, that is primarily the fault of the site’s developer – they have erected barriers to the user. However, a plain text equivalent is not any kind of help. I said towards the beginning of this article that "A website, in it’s simplest form, could be considered nothing more than an unorganized collection of hyperlinks and text.". This is what you get when you upload a plaintext version of your site to the web. Is this accessible? Emphatically not. It does not contain any of the barriers added by the designer, but it is not accessible.

The key which is missing from a plaintext document is organization. Removing semantic organization from a document does not add accessibility. Screen readers are capable of navigating quickly through HTML headers – plain text has none. Skiplinks can provide quick navigation between sections of a document – which will be absent in a plain text version. Plain text may be more accessible than the original document, if that document is badly inaccessible, but it is a mistake to consider plain text a suitable substitute for accessible development.

But to get back to the point, if you have created an inaccessible website it is do to your own actions. It is because you have erected barriers which prevent disabled users from accessing your content. It’s not because you have failed to add accessibility; it’s because you have prevented it.