who injured his back, rendering him physically unable to perform his cargo-handling job. Invoking seniority, he transferred to a less-demanding mailroom job, but this position later became open to seniority-based bidding and was bid on by more senior employees. Barnett requested the accommodation of being allowed to stay on in the less-demanding mailroom job. US Airways denied his request, and he lost his job. The Supreme Court decision invalidated both the approach of the district court, which found that the mere presence and importance of the seniority system was enough to warrant a summary judgment in favor of US Airways, as well as the circuit court's approach that interpreted 'reasonable accommodation' as 'effective accommodation.' Access Now v. Southwest Airlines Access Now, Inc. v. Southwest Airlines Co. was a 2002 case where the District Court decided that the website of Southwest Airlines was not in violation of the Americans with Disabilities Act, because the ADA is concerned with things with a physical existence and thus cannot be applied to cyberspace. Judge Patricia A. Seitz found that the "virtual ticket counter" of the website was a virtual construct, and hence not a "public place of accommodation." As such, "To expand the ADA to cover 'virtual' spaces would be to create new rights without well-defined standards." Ouellette v. Viacom International Inc. Ouellette v. Viacom International Inc. (2011) held that a mere online presence does not subject a website to the ADA guidelines. Thus Myspace and YouTube were not liable for a dyslexic man's inability to navigate the site regardless of how impressive the "online theater" is. Authors Guild v. HathiTrust Authors Guild v. HathiTrust was a case in which the District Court decided that the HathiTrust digital library was a transformative, fair use of copyrighted works, making a large number of written text available to those with print disability. Zamora-Quezada v. HealthTexas Medical Group Zamora-Quezada v. HealthTexas Medical Group (begun in 1998) was the first time this act was used against HMOs when a novel lawsuit was filed by Texas attorney Robert Provan against five HMOs for their practice of revoking the contracts of doctors treating disabled patients. In 1999, these HMOs sought to dismiss Provan's lawsuit, but a federal court ruled against them, and the case was settled out of court. Many decisions relating to Provan's unique lawsuit against these HMOs have been cited in other court cases since. Campbell v. General