II. GENERAL NONDISCRIMINATION REQUIREMENTS
12. Defendant, and each of its officers, employees, agents, successors, and assigns, and all others in active concert or participation with Defendant, are permanently enjoined from:
a. Discriminating against an individual on the basis of disability or taking any other action in violation of Title III of the ADA, 42 U.S.C. §§ 12181 - 12189; Section 503 of the ADA, 42 U.S.C. § 12203; or the Title III Regulation, 28 C.F.R. pt. 36;
b. Failing or refusing to design and construct QuikTrip Stores that are readily accessible to and usable by individuals with disabilities in full compliance with 42 U.S.C. § 12183(a)(1), 28 C.F.R. §§ 36.401 and 36.406, and the ADA Standards;
c. Failing or refusing to make alterations to QuikTrip Stores in full compliance with 42 U.S.C. § 12183(a)(2), 28 C.F.R. §§ 36.402 - 36.406, and the ADA Standards;
d. Failing or refusing to remove barriers at QuikTrip Stores where readily achievable in full compliance with 42 U.S.C. § 12182(b)(2)(iv) [sic] and 28 C.F.R. § 36.304;
e. Failing or refusing to make reasonable modifications in policies, practices, or procedures, when such modifications are necessary to afford individuals with disabilities an equal opportunity to access goods, services, facilities, privileges, advantages, or accommodations in full compliance with 42 U.S.C. § 12182(b)(2)(A)(ii) and 28 C.F.R. § 36.302;
f. Failing or refusing to maintain accessible features in operable working condition in full compliance with 28 C.F.R. § 36.211; and
g. Failing or refusing to take any action, or refrain from taking any action, when necessary to avoid discrimination against an individual on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any and all QuikTrip Stores, 42 U.S.C. § 12182(a).
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