Last week, Buzzfeed reported that the United Spinal
Association opposed Uber's CEO's nomination for Time
Magazine's Man of the Year award because Uber cars are
allegedly not wheelchair accessible. This controversy raises
an important and novel question: Are online-only businesses
like Uber and Airbnb covered by Title III of the ADA, and what
would coverage mean when the businesses don't own or operate
the vehicles or accommodations that customers use?
Uber provides transportation services to the public through a
mobile app that connects independent drivers and their vehicles
with customers. Uber does not employ the drivers, own any vehicles,
or have a physical place of business to serve customers.
Airbnb is a similar service for transient lodging. Airbnb,
through its website and mobile app, connects renters with people
who have overnight accommodations that they want to rent and
processes the payment. Like Uber, Airbnb is a web-only
business that does not own or
