United States of America, Plaintiff, v. Cinemark USA, Inc., Defendant - Consent Order

K.      Cinemark filed counterclaims and affirmative defenses alleging, among other things, that the DOJ acted unlawfully by attempting to retroactively change the meaning and interpretation of ADA Standard 4.33.3, that the DOJ failed to comply with the Administrative Procedures Act in promulgating, announcing, and attempting to enforce its interpretation of Standard 4.33.3, that the DOJ's interpretation illegally deprived Cinemark of due process, that Cinemark relied in good faith on state approvals when constructing its theaters, and that the DOJ should be estopped from invalidating those approvals.