Sued by KSS Law? What a New York Business Owner Needs to Know

If you just received a summons and complaint naming KSS Law PLLC, or attorney Kimmia Salehi, you are not alone. KSS Law files ADA accessibility lawsuits against businesses in New York State Supreme Court in Brooklyn, the Bronx and Manhattan, and new KSS Law cases show up in those courts regularly.

My name is Michael Samuel. I am an ADA defense attorney in New York, admitted in 1993, and I have defended about 100 ADA cases since 2019, most of them about websites. This article explains who filed your lawsuit, what it asks for, what your deadline is, and what a defense realistically looks like.

The most important fact first. These cases are in state court, not federal court, and the deadline works differently. You generally have 20 days to respond if the papers were handed to you personally in New York, and 30 days if they were served another way. For many businesses, the clock started on a day nobody noticed. The deadline section below explains why.

KSS Law PLLC is the law firm of New York attorney Kimmia Salehi. Her name already appears on the federal court records. In April 2024, as an attorney with Mars Khaimov Law, PLLC of Hicksville, she filed 11 website accessibility lawsuits in Manhattan federal court for one blind plaintiff, Sanjay Sookul, against 11 different businesses, all within two days. All 11 of those cases are now closed.

The same plaintiff, through the same firm, was also behind Sookul v. Fresh Clean Threads (2024), one of the Manhattan federal decisions holding that the ADA doesn’t cover a business that exists only online. Today KSS Law files in state court, where claims under New York State and New York City human rights law sit alongside the ADA.

None of that makes your lawsuit less real. A KSS Law complaint is a court case with a deadline, and it should be treated that way from the day it arrives.

Website accessibility complaints from this attorney follow a familiar pattern. Her 2024 federal complaints, for example, were class actions with a jury demand that stacked five claims on one set of facts: the ADA, the New York State Human Rights Law, the New York Civil Rights Law (which they said entitled the plaintiff to $500 per violation), the New York City Human Rights Law, and a request for a court declaration.

Each piece asks for something different. The ADA claim asks for an order to fix the website plus attorney’s fees. The money comes from the state and city law claims. The complaint will also name a plaintiff who says they are blind and use a screen reader, describe a visit to your website, list the barriers they say they hit, and say they intend to come back.

Those last details matter more than they look, because they are where many defenses begin. See how to read an ADA lawsuit complaint, or upload yours to our free complaint checker for a plain-English summary of who is suing, what they want and the date to plan around.

The basic rule. In New York state court you generally have 20 days to respond if the summons was handed to you personally in New York, and 30 days if it was served another way. The deadline is counted from service, not from the day you happened to read the papers.

The trap. Many corporations and LLCs are served through the New York Secretary of State. Service is complete when the Secretary of State receives the papers. The state then mails a copy to whatever address your business has on file, which may be an old office, a former accountant or a registered agent nobody checks. By the time the papers reach you, much of your time may already be gone.

What happens if you miss it. If you don’t respond in time, the plaintiff can ask the court for a default judgment, and you lose the chance to argue any of the defenses below. If you’re unsure when you were served, have a lawyer check the court file and the affidavit of service right away.

Don’t call KSS Law yourself. Let your lawyer make the first contact. What you say can be used in the case, and the first conversation often sets the tone for any resolution.

Standing. A plaintiff has to show a real injury and a real intention to return to your website. When the same plaintiff files dozens of near-identical lawsuits, courts look at those claims harder. In June 2026, in Sumlin v. Royal Batch, the Manhattan state court dismissed a website accessibility complaint we defended, finding the serial plaintiff’s standing allegations inherently incredible. In July 2026, in Alexandria v. Just Shades, the same court dismissed another complaint we defended in its entirety; that plaintiff had filed 54 near-identical lawsuits. Both decisions, with the index numbers, are on our results page. Prior results do not guarantee a similar outcome.

Online-only businesses. Some New York federal judges have ruled the ADA doesn’t cover a business with no physical store. In state court, the ADA claim isn’t the only one, and the city law covers any “place or provider” of public accommodation, so this argument helps less on its own. See can an online-only business be sued under the ADA.

Fixing the site, done right. A properly fixed and documented website can take the ADA claim off the table and protects you from the next plaintiff, but it doesn’t erase the state and city claims by itself. See whether to fix your website before or after you respond.

Resolving it early. Many of these cases end in a negotiated resolution. When that’s the right answer, getting there early, before fees build up on both sides, usually costs less. See how much it costs to settle an ADA website case.

Michael Samuel has defended about 100 ADA cases since 2019, most of them about websites. For website cases, the firm charges a flat fee that covers all work up to trial, including a motion to dismiss.

When a client’s site is being fixed, we line up the timing and the documentation with the legal strategy, so the work counts in the case and not just on the site.

For the website itself, we work with Codexyo, an independent web accessibility team that fixes sites like yours. They are not lawyers, and you’re free to use anyone.