Re: Target and NFB agree to Settlement

Is the press release (see below) a good enough "Abstract" or "Executive 
Summary" for you? Or are you looking for a summary of the settlement 
itself? 

Once you get past all the legal mumbo jumbo at the beginning of the 
settlement document, I found the information in the middle (section 8 & 9 
for example) of the settlement quite clear and informative about 
Monitoring and Training.  I quote: 

8. Monitoring. 
1.      The NFB will monitor the Target.com website as follows: 
1.      Quarterly testing.  NFB will run an automated monitoring tool 
called Worldspace on Target.com every quarter and will report to Target 
any results that reflect a deviation from the standard set forth in 
Section 6.1.  The parties recognize that automated monitoring tools may 
report “false positives” that do not establish deviation from the standard 
set forth in Section 6.1. 
2.      Annual user testing.  NFB will annually report to Target the 
results of user testing by 5 to 15 blind persons with varying skill levels 
and using JAWS, each attempting to complete the same tasks on at least 
five, but no more than ten of the transaction paths listed in Exhibit E. 
3.      Annual technical assessment by consultant.  Jim Thatcher, or if 
Mr. Thatcher is unable to continue as technical consultant, another 
consultant proposed by NFB and approved by Target, will annually make a 
technical assessment of up to 40 pages on the site selected by the 
consultant at his or her discretion, including but not be limited to, the 
home landing page, browse page of a major category, search results, 
product detail page, add to cart page, guest sign in, guest registration, 
address book, payment methods, billing address, place order, and thank you 
page.  The consultant will issue a report that includes, for each page 
tested, the URL, the date reviewed, and a screen shot of the page. The 
report will include a table following each screen shot that lists any 
accessibility issues that the consultant finds on the corresponding page. 
These issues can be problems, i.e., violations of the guidelines, or they 
may be things that are especially well done and worthy of note.  Each 
issue will be keyed to the guideline or standards involved and a severity 
or priority will be indicated.  The last column of the table will contain 
any suggested changes to address the issue. 
4.      New templates.  As Target develops additional templates, it shall 
notify NFB.  If Target timely requests that NFB test the additional 
template in advance of its production on Target.com, NFB will do so and 
report the results.  Any additional templates developed during the term of 
this Agreement may also be the subject of quarterly and annual testing. 
2.      NFB shall notify Target if it identifies concerns about the 
accessibility of the Target.com website.  Communications between NFB and 
Target pursuant to this provision shall take place between one individual 
designated by NFB and one individual designated by Target for this 
purpose.  
3.      Periodic Payments for Monitoring 
1.      Target shall provide periodic payments to the NFB for monitoring.  
NFB may use these monitoring funds to pay consultants and counsel for work 
related to the monitoring of the Target.com website. 
2.      Target shall make a first payment of fifty thousand (50,000) 
dollars within one (1) month of the Finality Date.  Target shall make a 
payment of forty thousand (40,000) dollars each year thereafter, within 
twelve (12) months of the previous payment, through the Term of the 
Agreement. 
9. Training. 
1.      Through the term of the Agreement, NFB shall provide at a location 
to be determined by Target periodic one-day training sessions regarding 
website accessibility to Target employees responsible for coding the 
Target.com website.  Each such employee shall attend one such training 
session during his or her employment at Target.  
2.      Within sixty (60) days after each such training session, NFB shall 
submit to Target documentation of actual expenses incurred in the 
provision of this training.  Target shall pay NFB the amount of documented 
actual expenses up to a limit of fifteen thousand (15,000) dollars per 
session. 
 
Regards,
Phill Jenkins

National Federation of the Blind and Target Agree to Class Action 
Settlement
8/27/2008

FOR IMMEDIATE RELEASE
CONTACT:
Chris Danielsen                                         Target 
Communications
Public Relations Specialist                          (612) 696-3400
National Federation of the Blind
(410) 659-9314, extension 2330
(410) 262-1281
cdanielsen@nfb.org

National Federation of the Blind and Target Agree to Class Action 
Settlement

Target Will Ensure That Web Site Remains Accessible to Guests Who Use 
Assistive Technologies

Baltimore, Maryland (August 27, 2008): The National Federation of the 
Blind (NFB) and Target (NYSE: TGT) announced today that they have settled 
a class action lawsuit regarding access to the Target.com Web site by 
blind people.

Dr. Marc Maurer, President of the National Federation of the Blind, said: 
"Access to Web sites is critical to the full and equal participation of 
blind people in all aspects of modern life.  The National Federation of 
the Blind is pleased to have reached a settlement with Target that is good 
for all blind consumers, and we recognize that Target has already taken 
action to make certain that its Web site is accessible to everyone.  We 
look forward to working with Target in the coming months to help make 
additional improvements that will enhance the experience of blind visitors 
to Target.com.  It is our sincere hope that other businesses providing 
goods and services over the Internet will follow Target's example and take 
affirmative steps to provide full access to their Web sites by blind 
consumers."

Bruce Sexton, Jr., a named plaintiff in the case from the beginning, 
added:  "This settlement marks a new chapter in making Web sites 
accessible to the blind.  I commend Target for committing to being a 
leader in online accessibility."

Steve Eastman, president of Target.com, said: "First and foremost, Target 
is committed to serving all our guests.  As our online business has 
evolved, we have made significant enhancements in order to provide an 
accessible shopping experience.  We are pleased to have reached an 
agreement with the National Federation of the Blind regarding the 
accessibility of Target.com for individuals who use assistive technologies 
and will work with the NFB on further refinements to our Web site."

As part of the settlement, Target will establish a $6 million fund from 
which members of the California settlement class can make claims.  In 
addition, the National Federation of the Blind will certify the Target Web 
site through its Nonvisual Accessibility Web Certification program once 
agreed upon improvements are completed in early 2009.  Target and NFB have 
agreed to a three-year relationship during which NFB will perform 
accessibility testing of the Target Web site.  For more information about 
the terms of the settlement, please visit www.nfbtargetlawsuit.com.

About the National Federation of the Blind - With more than 50,000 
members, the National Federation of the Blind is the largest and most 
influential membership organization of blind people in the United States. 
The NFB improves blind people's lives through advocacy, education, 
research, technology, and programs encouraging independence and 
self-confidence.  It is the leading force in the blindness field today and 
the voice of the nation's blind.  In January 2004 the NFB opened the 
National Federation of the Blind Jernigan Institute, the first research 
and training center in the United States for the blind led by the blind.

About Target -  Minneapolis-based Target serves guests at 1,648 stores in 
47 states nationwide by delivering today's best retail trends at 
affordable prices. Target is committed to providing guests with great 
design through innovative products, in-store experiences and community 
partnerships. Whether visiting a Target store or shopping online at 
Target.com, guests enjoy a fun and convenient shopping experience with 
access to thousands of unique and highly differentiated items. Target 
(NYSE:TGT) gives more than $3 million a week to its local communities 
through grants and special programs. Since opening its first store in 
1962, Target has partnered with nonprofit organizations, guests and team 
members to help meet community needs.

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