Patreon Digital Accessibility Agreement

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Congratulations to Patreon! Posted here is the digital accessibility settlement agreement the company reached with the American Council of the Blind and individual blind creators and patrons, including Robert Kingett.

The agreement is designed to ensure that Patreon’s website and mobile application are available to people with and without disabilities. Patreon will use the Web Content Accessibility Guidelines 2.1 AA and the Authoring Tool Accessibility Guidelines 2.0 as part of its accessibility program.

Patreon participated in Structured Negotiation — no lawsuit was needed or filed. The Law Office of Lainey Feingold and Washington, D.C. civil rights lawyer Matt Handley of Handley Farah & Anderson were the lawyers for the blind individuals and organization.

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SETTLEMENT AGREEMENT

This Settlement Agreement (“Agreement”) and the related and incorporated document entitled Confidential Addendum to Settlement Agreement (collectively referred to as the “Full Agreement”) are entered into by and between the American Council of the Blind, Robert Kingett and Anthony Stephens (collectively referred to as “Claimants”) on the one hand and Patreon (which includes Patreon, Inc., Patreon Ireland Limited, and its branches, collectively referred to as “Patreon”) on the other hand. Together Claimants and Patreon are referred to as the Parties.

RECITALS

This Agreement is based on the following facts:

1.
Claimant American Council of the Blind is a national organization of blind, visually impaired and sighted individuals whose purpose is to work toward independence, security, equality of opportunity, and improved quality of life for all blind and visually impaired people.
2.
Claimant Robert Kingett is a person with a visual impairment who resides in Illinois and is a Patreon member.
3.
Claimant Anthony Stephens is a person with a visual impairment who resides in Maryland and is a Patreon member.
4.
Patreon is an American membership platform that provides business tools for creators to run a subscription content service, with ways for artists to build relationships and provide exclusive experiences to their subscribers, or “patrons.” Patreon maintains a website and mobile applications for use by its members and those who want to fund their members.
5.
In December 2018, the Parties agreed to enter into Structured Negotiations in connection with the claims Claimants raised concerning accessibility barriers on Patreon’s website and mobile applications. Since that time, the Parties have worked together in good faith to resolve those claims.
6.
The Parties enter into this Agreement to resolve Claimants’ claims and to avoid the burden, expense, and risk of litigation. In entering into this Agreement, Patreon does not admit, and specifically denies, that it has violated or failed to comply with any provisions of the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101, et seq., (“ADA”), the implementing regulations of Title III of the ADA, 24 C.F.R. Part 36, and any applicable laws of any state relating to accessibility for persons with disabilities, any regulations or guidelines promulgated pursuant to those statutes, or any other applicable laws, regulations, or legal requirements. Neither this Agreement, nor any of its Exhibits, Addenda, terms or provisions, nor any of the negotiations connected with it, shall be construed as an admission or concession by Patreon of any such violation or failure to comply with any applicable law. Neither this Agreement and its terms and provisions, including these Recitals, nor the Confidential Addendum shall be offered or received as evidence for any purpose whatsoever against Patreon in any action or proceeding, other than a proceeding to enforce the terms of the Full Agreement.

NOW, THEREFORE, the Parties agree as follows:

1. Definitions.

As used in the Full Agreement, the following terms mean:

1.
Access Standard: The standard for web accessibility is defined as Web Content Accessibility Guidelines (“WCAG”) 2.1 Conformance Level AA, as further outlined in Section 3.1 of this Agreement.
2.
Accessible PDF: A PDF document that satisfies International Standards Organization (ISO) 14289, also known as PDF/UA (PDF/Universal Accessibility) standard.
3.
Claimants’ Counsel: Handley Farah & Anderson PLLC, The Law Office of Lainey Feingold, and the attorneys practicing law therein.
4.
Effective Date: April 15, 2020.
5.
Patreon Application(s) for Mobile Devices (or “Patreon Mobile App(s)”): Mobile applications for iOS and Android smartphones and tablets published by Patreon for its members and the general public.
6.
Patreon Website: The website (including pages only available to Patreon members) at patreon.com.
7.
Person(s) with a Visual Impairment: Any person who has a physical, mental or sensory impairment that substantially limits him or her in the major life activity of seeing.
8.
Third-Party Vendor: A third party who enters into a written contract with Patreon from March 1, 2020 to perform paid services for its services on Patreon’s website or mobile app.
9.
Third-Party Content means web content, other than User-Generated Content, that is generated by a third party and not created or controlled by Patreon.
10.
User-Generated Content means content on Patreon’s on-line platform that is generated by Patreon members and users and not created by Patreon.

2. Duration of Agreement.

The terms of the Full Agreement shall remain in effect from the Effective Date through March 31, 2022.

3. Accessibility Provisions.

3.1
Patreon will use reasonable efforts to ensure that the Patreon Website and Mobile Apps conform to the Web Content Accessibility Guidelines (“WCAG”) 2.1 Conformance Level AA by or before December 31, 2021, and will use reasonable efforts to adhere to the benchmarking deadlines set forth in the Exhibits A and B to this Agreement. The Parties acknowledge that some WCAG Conformance Level AA Success Criteria address features or design elements that may not be used on the Patreon Website or Mobile Apps, and in such circumstances conformance with those Success Criteria will not be required.
3.2
New features, functions or changes to the Patreon Website or Mobile Apps that are initiated on or after the Effective Date will conform to the Access Standard when the new feature, change, or site element is launched.
3.4
Beginning on the Effective Date, Patreon will include information about accessibility improvements, as applicable, in the release notes for new Patreon Website or Mobile App releases.
3.5
The Parties recognize that Patreon may encounter unforeseen complications in meeting the accessibility timelines set forth in the Exhibits. Therefore, if Patreon determines it is necessary to extend any date(s) in this Agreement, including Exhibits A and B, for a period of ninety days or fewer, Patreon shall notify Claimants of the new date as soon as Patreon determines the new date. If Patreon proposes to extend any date by greater than ninety days, Patreon will provide Claimants with the new proposed schedule(s), and the reason(s) for the extension, and the Parties will negotiate a new date in good faith. Disputes regarding a requested extension of greater than ninety days will be resolved pursuant to Section 8 of this Agreement.
3.6
Accessible PDFs.

3.6.1
Patreon does not typically use PDF on its Website or Mobile App to communicate with creators, patrons, users, or other third parties. To the extent Patreon uses a PDF to interact with creators, patrons, users, or other third parties, Patreon will use Accessible PDFs starting January 1, 2020.
3.7
CAPTCHA. If any Completely Automated Public Turing Test to Tell Computers and Humans Apart or similar visual or textual Turing or reverse-Turing verification test (commonly known as “CAPTCHA”) is used on the Patreon Website or Mobile Apps, Patreon will incorporate alternative security measures that are usable by Persons with Visual Impairments.
3.8
Third-Party Content. Patreon’s only obligations under this Settlement Agreement with respect to Third-Party Content are the following:

3.8.1
Testing and Communications with Third Party Vendors. From March 1, 2020, and periodically throughout the Term of the Agreement, Patreon will use reasonable efforts to test customer-facing Third-Party Content on the Patreon Website and Mobile Apps to determine if it conforms to the Access Standard. Where Patreon finds content that does not conform to the Access Standard, or where Claimants notify Patreon of such content, Patreon will, within thirty (30) days of that discovery or notice, request in writing that the particular third party(ies) supplying that content to Patreon bring their content into conformance with the Access Standard. Patreon will request a written response within thirty (30) days of its request.
3.8.2
Reasonable Efforts to Find Vendor Providing Accessible Content. If Patreon is notified that a third party vendor will not bring its content into conformance with the Access Standard, after making the efforts described in 3.8.1, Patreon will use reasonable efforts to find an alternative vendor that provides the content in conformance with the Access Standard, subject to Patreon’s existing contractual obligations to the third party vendor, and to obtain a new vendor that provides the same services at the same quality and same price and whose standards conform to Patreon’s internal third-party oversight requirements, including, but not limited to, elements relating to security, reliability, and regulatory requirements. Patreon will not be required to violate any confidentiality or other agreements with third parties for any purpose or to terminate any pending or existing third party vendor contract prior to its expiration date.
3.8.3
New Third-Party Content After March 1, 2020. If, on or after March 1, 2020, Patreon issues requests for proposals for development or inclusion of the customer-facing Third-Party Content on Patreon Website or Mobile App, Patreon will include conformance with the Access Standard as a component in all such requests for proposals. Patreon will use reasonable efforts to select third party vendors for customer-facing content who can conform to the Access Standard, provided that those vendors also meet all other criteria in the request for proposals. If Patreon extends contracts for Third-Party Content existing as of the Effective Date, Patreon will ask that vendor to include conformance with the Access Standard in the extended vendor contract. If the vendor is unable to do that, Patreon will use reasonable efforts to find an alternative third party vendor to provide the same service, meeting all required Patreon criteria for that service, who can conform to the Access Standard.
3.8.4
No later than March 1, 2020, Patreon will ensure that all Patreon staff involved in the procurement of Third Party Content have read and are familiar with the Accessible Technology Procurement Toolkit published by Disability:IN, available at https://private.disabilityin.org/procurementtoolkit/.
3.8.5
Patreon is not obligated under this Agreement to ensure User-Generated Content conforms with the Access Standard. However, Patreon will ensure that, no later than October 1, 2021, the tools on the Patreon Website and Mobile App support the production of accessible content, and that such tools conform with the Authoring Tool Accessibility Guidelines 2.0.

4. Miscellaneous Digital Accessibility Provisions.

4.1

Digital Accessibility Policy.

4.1.1
No later than March 1, 2020, Patreon will develop an internal policy regarding the accessibility of the Patreon Website and Patreon Mobile Apps (“Digital Accessibility Policy”) that, at a minimum, will include: (i) a statement of the Access Standard and Patreon’s commitment to use it; (ii) protocols for testing and measuring whether technology obtained from third party developers and vendors complies with the Access Standard; and (iii) methods by which Patreon clients can report web and mobile accessibility feedback and the process for addressing the feedback. Patreon will provide Claimants with a draft of the Digital Accessibility Policy prior to its being finalized. Claimants will provide their feedback on this draft policy within fifteen (15) days of receipt, and Patreon will consider the feedback provided by Claimants in good faith, and implement the policy within 30 days thereafter.
4.1.2
Patreon will use reasonable efforts to ensure the Digital Accessibility Policy is distributed, within 30 days of first implementation of the Policy and upon initial hire, and annually thereafter, to all employees, contractors, and Third Party Vendors who design, develop, maintain, or otherwise have responsibility for the Patreon Website and Patreon Mobile Apps, or who provide website or mobile content, technical support, or customer service.
4.2
Usability Testing.

4.2.1
Throughout the Duration of this Full Agreement, Patreon will consider in good faith feedback from Claimants regarding the accessibility and usability of the Patreon Website and Mobile Apps.
4.2.2
Patreon will use reasonable efforts to ensure that the Patreon Website and Mobile Apps are tested periodically throughout the Duration of this Agreement for usability by persons with disabilities and conformance with the Access Standard.
4.2.3
If, during the Duration of this Agreement, Patreon plans to include a new CAPTCHA on the Patreon Website, it will provide Claimants the opportunity to provide feedback on the alternative security measure to ensure that it is usable by them prior to the inclusion of the CAPTCHA on the Patreon Website. Patreon will also use reasonable efforts to ensure that the usability of any alternative security measure is tested prior to the inclusion of the CAPTCHA on the Patreon Website.
4.2.4
Patreon will give good faith consideration to all usability testing results and other feedback (collectively “Feedback”) provided pursuant to Section 4.2 consistent with the terms of this Agreement.
4.3
Additional Testing. Patreon will continue to ensure manual and user experience testing is used to help it assess Patreon Website’s and Mobile Apps’ conformance with the Access Standard. Patreon may also employ automated testing to supplement its manual and user testing. Patreon’s commitment to this additional testing will extend beyond the Term of this Agreement.
4.4
Mobile Resources. Patreon will ensure that employees who design, develop, maintain, or otherwise have responsibility for Patreon Mobile Apps are familiar with the following resources: (i) BBC Mobile Accessibility Standards and Guidelines at http://www.bbc.co.uk/guidelines/futuremedia/accessibility/mobile_access.shtml; (ii) Apple’s Accessibility for Developer resources at https://developer.apple.com/accessibility/; and (iii) Android Accessibility resources at https://developer.android.com/guide/topics/ui/accessibility/index.html.
4.5
Digital Accessibility Working Group. Patreon will maintain throughout the Duration of this Agreement, a Digital Accessibility Working Group comprised of personnel with responsibility for meeting the Access Standard. The Working Group will include a variety of individuals who design, develop, maintain, or otherwise have responsibility for the Patreon Website and Patreon Mobile Apps or who provide website or mobile content, technical support, training or customer service in connection with accessibility and usability of the Patreon Website and Mobile Apps to people with disabilities. The Working Group will meet as often as Patreon deems necessary to ensure compliance with the terms of this Agreement, but no less than semi-annually.

5. Accessibility Information on Patreon Website and Mobile Apps.

5.1
No later than January 31, 2020, Patreon will post Accessibility Statements on the Patreon Website and Mobile Apps. The page or tab will include, at a minimum: (i) information regarding Patreon’s efforts to conform to the Access Standard; (ii) information regarding use of the Patreon Website by Persons with Visual Impairments including usability tips; (iii) a web-based (or e-mail) and telephone-based method for Persons with Visual Impairments to contact Patreon regarding accessibility concerns; (iv) the following statement: “This site provides links to sites created and maintained by other companies and organizations. Patreon cannot assure that these other sites meet applicable accessibility standards.”, and (v) on Patreon’s Application Programming Interface landing page, Patreon will add the following statement, “Patreon is committed to providing accessible web content whenever possible. The functionality added here is developed by third-parties, and Patreon neither controls nor ensures the accessibility of features added by third parties. Patreon encourages developers to follow best practices in designing and building apps that work for everyone by adhering to Guidelines established by the Web Accessibility Initiative of the World Wide Web Consortium (www.w3.org/wai).” Patreon will consider in good faith accessibility resources provided by Claimants that are appropriate for Patreon’s Application Programming Interface (API) portal and link to those resources that Patreon determines will assist users of the API portal in developing accessible content.
5.2
Patreon will provide Claimants with a draft of the Accessibility Statements prior to its/their being finalized. Claimants will provide their feedback on this information within fifteen (15) days of receipt, and Patreon will consider the feedback provided by Claimants in good faith. The Accessibility Statements will, at a minimum, be available from an easily findable location on the Patreon Website home page common footer and all other pages. It will also be listed as a help topic on the Patreon Website’s Help page(s) and will be listed as a help topic within Patreon’s Mobile Apps.

6. Reporting.

Within 30 days of the end of each Quarter during the Duration of this Full Agreement, starting with the end of Q1 2020, Patreon will report the following information to Claimants in writing: (i) all portions of the Patreon Website and Mobile Apps that were remediated pursuant to the schedules in the Exhibits; (ii) any portions of the Patreon Website and Mobile Apps that were not remediated pursuant to the schedules in the Exhibits; (iii) the reasons why any of the dates in the schedule(s) were not met; and (iv) a proposed revised timeframe for completing the remediation that was not completed pursuant to the schedule(s) set forth in the Exhibits. If any Party requests to discuss this information following receipt of the report, the Parties shall promptly hold a telephonic conference for this purpose. Any issues that are not resolved through the Parties’ discussions will be handled as a dispute pursuant to Section 8 of this Agreement.

7. Training of Patreon Staff.

To ensure effective implementation of this Agreement, Patreon will provide training to appropriate staff as set forth in this Section.

7.1
Customer Service Staff. Patreon will provide training on the following subjects to customer service personnel who answer inquiries from Patreon members and from members of the general public: (i) appropriate communications with Persons with Visual Impairments; and (ii) how to route inquiries concerning digital accessibility issues to appropriate trained personnel for a timely response. Patreon will train new staff upon initial hire and will provide refresher training annually.
7.2
Technical Support Staff. No later than March 1, 2020, Patreon will offer training on the following subjects to personnel who answer member inquiries regarding website and mobile technical support and accessibility issues: (i) the types of assistive technology used by web and mobile device users who are Persons with Visual Impairments; (ii) the fact that many computer users with disabilities rely solely on a keyboard, and do not use a mouse, to navigate a website; (iii) the existence and content of the Accessibility Information Page; (iv) the existence and content of Patreon Digital Accessibility Policy; and (v) internal Patreon procedures for reporting, logging, and resolving web and mobile accessibility and usability complaints. Patreon will train new staff upon initial hire and will provide refresher training to these employees annually.
7.3
Web and Mobile Application Development Staff. During the course of the Parties’ negotiations, Patreon has developed and provided internal accessibility training for all Patreon employees responsible for ensuring that the Patreon Website and Mobile Apps conform to the Access Standard, including employees responsible for the procurement of Third Party Vendors. Patreon will provide the same or similar training to new employees, as appropriate, upon initial hire and will provide refresher training to all employees annually.

8. Procedures in the Event of Disputes.

8.1
Notice of Non-Compliance. If a Party believes that any other Party has not complied with any provision of the Full Agreement, that Party shall provide the other Party with Notice of Non-Compliance containing the following information: (i) the alleged act of non-compliance; (ii) a reference to the specific provision(s) of the Settlement Agreement or Confidential Addendum that are involved; (iii) a statement of the remedial action sought by the initiating Party; and (iv) a brief statement of the specific facts, circumstances and legal argument supporting the position of the initiating Party.
8.2
Response. Within thirty (30) days of receipt of a Notice provided pursuant to Section 8.1, the non-initiating Party shall respond to the initiating Party in writing.
8.3
Meet and Confer. Within two weeks after the response described in Section 8.2, the Parties shall informally meet and confer and attempt to resolve the issues raised in the Notice.
8.4
Submission to Mediation. If the matters raised in a Notice provided pursuant to 8.1 are not resolved within sixty (60) days of the initial meet and confer required by Section 8.3, either Party may submit the unresolved matters to nonbinding mediation before a mutually agreed upon mediator affiliated with Judicial Arbitration & Mediation Services (“JAMS”), or such other mediator as the Parties may jointly designate.
8.5
Submission to Arbitration. If mediation fails to resolve the matter, the Parties then will settle the matter finally by means of arbitration conducted by JAMS pursuant to its Streamlined Arbitration Rules and Procedures at a mutually convenient location. The award of the arbitrator will be enforceable in a court of competent jurisdiction.

9. Notice or Communication to Parties.

Any notice or communication required or permitted to be given to the Parties shall be given in writing by e-mail and by overnight express mail or United States first class mail, addressed as follows:

To: Claimants:

Matthew Handley
Handley Farah & Anderson PLLC
777 6th Street NW
Eleventh Floor
Washington, DC 20001
[email deleted for web posting]

Lainey Feingold (by email only)
Law Office of Lainey Feingold
[email deleted for web posting]

To: Patreon:

Joseph Lynette
Jackson Lewis P.C.
44 South Broadway
14th Floor
White Plains, NY 10601
[email deleted for web posting]

Priya Sanger
Patreon
600 Townsend Street Suite 500
San Francisco, CA 94103
[email deleted for web posting]

10. Publicity Regarding This Agreement and Its Terms.

The Parties will issue a joint press release on or about March 31, 2020. If the Parties cannot agree on a joint press release, either Party may issue its or their own press release, provided that: (i) the content is consistent with this Agreement; (ii) reflects the Parties’ collaboration; and (iii) a copy of the release is provided to all Parties and their counsel at least ten business days before it is sent to the press. The Parties agree not to issue any press release related to this Agreement except as described in this Section.

11. Agreement Binding on Assigns and Successors; No Third Party Beneficiaries.

11.1
Assigns and Successors. This Full Agreement shall bind any assigns and successors of the Parties, who have the right to implement the actions required.
11.2
No Third Party Beneficiaries. This Full Agreement is for the benefit of the Parties hereto only and no other person or entity shall be entitled to rely hereon, receive any benefit herefrom, or enforce against any Party any provision hereof. The Parties specifically intend that there be no third party beneficiaries to this Full Agreement.

12. Force Majeure.

The performance of Patreon under this Full Agreement shall be excused during the period and to the extent that such performance is rendered impossible, impracticable or unduly burdensome due to acts of God, strikes or lockouts, unavailability of parts, equipment or materials through normal supply sources, security threat, or any other event of force majeure. If Patreon seeks to invoke this Section, it shall notify Claimants in writing as soon as reasonably practicable, specifying the particular action(s) that could not be performed and the specific reason for non-performance. Claimants’ Counsel and Patreon will thereafter meet and confer regarding an alternative schedule for completion of the action that could not be performed, or an alternative action. Any dispute regarding the applicability of this Section, or any future action to be taken, that remains after the meet and confer session will be handled as a dispute pursuant to Section 8 of this Agreement.

13. Recitals and Exhibits.

The terms of any Recital or any Exhibit attached hereto are fully incorporated into this Full Agreement and are an integral part thereof. The terms of this Full Agreement, where applicable, are fully incorporated into all Exhibits and are, where applicable, an integral part thereof. The use of the terms “Agreement” and “Full Agreement” herein includes the Exhibits.

14. Multiple Originals/Execution in Counterparts.

Each Party and Claimants’ Counsel shall sign one copy of this document and each such copy shall be considered an original. This document may be executed in counterparts and facsimile and PDF signatures shall be accepted as original.

15. Non-Admission of Liability.

In entering into the Full Agreement, Patreon does not admit, and specifically denies, that it has violated or failed to comply with the ADA or any other law related to accessibility.

16. Integrated Agreement.

The Full Agreement constitutes the entire agreement of the Parties relating to the subject matters addressed therein.

17. Modification Based on Change of Law or Regulations.

If, after the Effective Date, either Party believes that there is a change in any applicable law or regulation which requires a modification of this Agreement because it imposes a different obligation than provided in this Agreement, the Party shall notify the other Party in writing. The notification will include the way in which the Party contends the Agreement should be modified as a result of the change in law or regulation. The proposed modification will become effective thirty days after such notification unless the other Party objects in writing to the proposed modification. In the event of a disagreement between the Parties over the appropriate modifications to the Agreement as contemplated by this Section, the Parties shall meet and confer and shall work together in good faith to resolve the disagreement. Failure to reach agreement during such meet and confer shall be considered a dispute to be resolved pursuant to Section 8.

Exhibit A: Schedule for Website Remediation

Patreon will use reasonable efforts to meet the following schedule while remediating access barriers on the Patreon Website, as set forth in Section 3.1 of the Agreement:

Completed no later than October 31, 2019

  • Navigation redesign which adheres to Web Content Accessibility Guidelines (“WCAG”) 2.1 Conformance Level AA (“Access Standard”)
  • Resolution of bug so that user can open links in new tab via Ctrl/Cmd + click
  • Creator coloring feature with color names compliant with Access Standard
  • Development of an a11y QA plan with input from the executive team
  • Refine existing iconography library and ensure it has appropriate labels/focus states compliant with the Access Standard.

Completed no later than December 31, 2019

  • Complete the following accessibility fixes in the foundational User Interface layer, specifically:
    • Pill buttons
    • Radio buttons
    • Select (use of native on mobile instead of custom-built)
    • NumericInput
  • Build a tooling and monitoring system to measure how accessible a given product surface area is against the Access Standard
  • Implement the following foundational UI layer (Design System) accessibility improvements
  • Redesign modals such that they are compliant with the Access Standard
  • Redesign and rewrite popovers/tooltips to have keyboard interactivity compliant with the Access Standard

Completed no later than March 31, 2020

Enable keyboard interaction to Pinned Post Feature to make it accessible to screenreader users

Completed no later than June 30, 2020

  • Implement the following Foundational UI layer (Design System) accessibility improvements
    • Redesign general page layouts such that they are compliant with the Access Standard
    • Redesign loading indicators such that they are compliant with the Access Standard
    • Redesign alert/banner system such that it is compliant with the Access Standard
    • Redesign form elements (inputs, selects, checkboxes, etc.) such that they are compliant with the Access Standard

Completed no later than December 31, 2020

  • Implement the following Foundational UI layer (Design System) accessibility improvements
    • Redesign tables such that they are compliant with the Access Standard
    • Redesign secondary navigation (not the top banner, but the secondary level after that (horizontal nav lists, etc.)) such that it is compliant with the Access Standard
    • Redesign step-progress indicators such that it is compliant with the Access Standard
    • Redesign emails such that they are compliant with the Access Standard

Completed no later than June 30, 2021

  • Implement the following Foundational UI layer (Design System) accessibility improvements
    • Redesign analytics components, such as line and bar charts, such that they are compliant with the Access Standard
    • Redesign breadcrumbs, such that they are compliant with the Access Standard

Completed no later than December 31, 2021

  • Complete audit of website to ensure compliance with the Settlement Agreement.

Exhibit B: Schedule for Mobile Application Remediation

Patreon will use reasonable efforts to meet the following schedule while remediating access barriers on the Patreon Mobile Applications, as set forth in Section 3.1 of the Agreement.

Completed no later than March 31, 2020

Complete full audit of mobile native apps (iOS, android) to identify areas that are not compliant with the Access Standard.

Completed no later than June 30, 2020

  • Ensure post creation and viewing is compliant with Access Standard
  • Ensure that creator home screen is compliant with Access Standard

Completed no later than December 31, 2020

  • Ensure message creation and viewing is compliant with Access Standard
  • Ensure all web views used by mobile native apps (pledge flow, new user signup, etc.) are compliant with Access Standard
  • Ensure that in-app notifications, settings, and creator insights screens are compliant with Access Standard

Completed no later than December 31, 2021

Complete full 3rd party audit of mobile native apps (iOS, android) to ensure compliance with the Settlement Agreement.