The Authors Guild, Inc. et al v. Hathitrust et al
DECLARATION of James Fruchterman in Support re: 74 MOTION for Summary Judgment.. Document filed by Georgina Kleege, Blair Seidlitz, The National Federation of the Blind, Courtney Wheeler. (Goldstein, Daniel)
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
THE AUTHORS GUILD, INC., et al.,
Case No. 11-cv-635l(HB)
HATHITRUST, et al.,
SECOND SUPPLEMENTAL DECLARATION OF .TAMES FRUCHTERMAN
IN SUPPORT OF DEFENDANT INTERVENORS' MOTION FOB SUMMARY
I, James Fruchtennan, do hereby declare that:
1. To reproduce. and distribute high quality digital copies of texts to individuals with print
disabilities, Bookshare® has found it necessary to grant employees, subcontractors and
volunteers, who arc primarily sighted people without print disabilities, full access to the texts of
the digital books and pcriodical.s.
2. It is a fundamental requirement for accessibiLity work that people without print
disabilities are the pdmacy personnel used to make accessible versions of inaccessible content.
To put it simply, if blind people could easily and automatically gain full access to printed books
and graphics, they wouldn't need the help of sighted people to enter, proofread, fonnat or
describe such books t:o create accessible versions.