Two federal courts in New York recently joined the growing list of those finding that Title III of the Americans with Disabilities Act (ADA) does apply to websites. Both courts denied motions to dismiss by businesses that had argued that Title III of the ADA only applied to physical locations of public accommodation. These decisions came shortly after a federal court in Florida-on which we previously reported in June-concluded that the website of grocery store Winn-Dixie was required to comply with the ADA because the goods and services offered on its website had a significant connection to those offered at its physical locations. The two recent New York cases, which involved retail store Blick Art Materials and burger chain Five Guys, took the Winn-Dixie decision a step further. The courts held that websites must be ADA compliant regardless of whether the online content has a nexus to a physical location.