On June 19, 2012, the federal District Court of Massachusetts became the first federal court to hold that the Americans with Disabilities Act’s (ADA) accessibility requirements apply to website-only businesses. The National Association of the Deaf filed this lawsuit claiming that Netflix violated the ADA by failing to offer closed captioning for all of its Internet streamed movies. The company filed a motion seeking judgment on this claim, arguing that the ADA’s requirements for “public accommodations” apply only to physical structures. Rejecting this argument and allowing the claim to move forward, the Court held that limiting the ADA’s reach to only tangible places and physical structures would frustrate the purpose of the ADA. This decision, which will almost certainly be appealed, demonstrates the challenges for businesses as courts seek to apply the ADA’s requirements to Internet-based companies. The Web is now the next battlefield in ADA litigation. Businesses should be prepared to see similar claims in other courts. The case is National Association of the Deaf v. Netflix, Case No. 3:11cv-30169 (D. Mass. June 19, 2012).