In June 2011, the National Association of the Deaf represented by the Disability Rights Education and Defense Fund (DREDF) filed a lawsuit against Netflix under the Americans with Disabilities Act over a lack of subtitles.[167] In October 2012, the parties agreed to a settlement under which Netflix agreed to pay $755,000 in legal fees, provide closed captioning for its entire library by 2014, and have captions available for all new content within 7 days by 2016.[168] In April 2015, the United States Court of Appeals for the Ninth Circuit issued an unpublished decision ruling that the ADA did not apply to Netflix in this case, as it is "not connected to any actual, physical place" and thus not a "place of public accommodation" that applies to the Act.[169]
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