In 1998, the United States filed a civil action against the NCAA by citing title III (prohibiting disability discrimination in a public accommodation/facility owned by a private entity) of the ADA. At the time, the NCAA required students to graduate with a 2.0 GPA, a certain minimum score on the SAT/ACT, and complete 13 “core courses” designated by the NCAA. However, up to that point, the NCAA had not been refusing to certify special education courses as “core courses.”