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S.D.N.Y.Procedural orderFiled Sept. 11, 2025

Thorne v. Bikes

Judge
Garnett
Docket
1:25-cv-03085
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureADA / Disability
In one sentence

In Braulio Thorne v. Karbon Bikes, Judge Garnett ordered settlement talks and a joint status letter without deciding the case.

Who this affects

Braulio Thorne and Karbon Bikes, LLC are required to participate in settlement discussions and submit the joint letter. Counsel who have appeared must also serve the order and the court’s Individual Rules and Practices as directed.

What happened

Braulio Thorne v. Karbon Bikes, LLC involves a dispute concerning a website and Title III of the Americans with Disabilities Act. The court stated that Karbon Bikes, LLC appeared to have been served.

The court ordered the parties to meet for at least one hour by October 31, 2025, to try in good faith to settle. They must consider whether Thorne has standing and whether the website is a business website without a physical location, which some courts have found is not a public accommodation under the disability law. By November 14, 2025, they must file a joint letter reporting whether they settled and, if not, requesting mediation, a settlement conference, or an initial status conference.

Judge Garnett stayed Karbon Bikes, LLC’s deadline to answer or otherwise respond until the joint letter is filed. The order did not decide standing, whether the website is covered by the disability law, or any other issue in the case.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Thorne v. Bikes · No. 1:25-cv-03085
Judge
Garnett
Date
Sept. 11, 2025

Nature of the Order

This is a case-management and settlement order, not a decision on the merits. The court stated that Karbon Bikes, LLC appeared to have been served. It directed the parties to pursue settlement and to report their plans for moving the case forward.

Issues Identified for Settlement Discussions

The court directed the parties to consider whether Plaintiff has satisfied the threshold requirement of standing. Standing is the legal requirement that a plaintiff have a sufficient personal stake in the dispute to ask a federal court for relief.

The parties were also directed to consider whether the website involved in the action is a “standalone website,” which the order described as a business website without a physical location. The order noted that some courts in the Southern District of New York have held that such websites are not “places of public accommodation” under Title III of the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq. The court did not resolve either issue.

Orders and Deadlines

The parties must meet and confer for at least one hour in a good-faith attempt to settle by October 31, 2025. If they cannot settle on their own, they must also discuss whether further settlement discussions through the district court’s mediation program or before a magistrate judge would be productive.

By November 14, 2025, the parties must file a joint letter stating whether they settled. If they did not settle, the letter must request either referral to mediation or a settlement conference before a magistrate judge, with a preference between those options, or an initial status conference. The letter must also state whether Karbon Bikes, LLC plans to answer or move to dismiss the complaint. If it plans to move to dismiss, the letter must briefly describe the anticipated basis in no more than one paragraph.

The deadline for Karbon Bikes, LLC to answer or otherwise respond to the complaint is stayed pending the joint letter. After the letter is filed, the court will set either a deadline for an answer or a briefing schedule for a motion to dismiss.

Service of the Order

Counsel who had entered appearances when the order issued must promptly provide the order and the court’s Individual Rules and Practices to counsel for parties who had not yet appeared, or personally to the party if counsel’s identity was unknown. They must also file proof that this notice was provided.

Disposition

The court entered the settlement and case-management directives described above. It did not grant or deny a motion, dismiss any claim, or decide the parties’ substantive rights.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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