Defendants argue that plaintiff's request for a pool lift constitutes a "modification" and not an "accommodation" under the statute because it modifies the physical property. (Mot. at 3-6.) However, defendants cite no authority to substantiate this distinction or, if this distinction does exist, to persuade the court that the distinction compels the court to dismiss this claim at this stage. In the Americans with Disabilities Act context, for example, the Ninth Circuit uses the terms "reasonable modification" and "reasonable accommodation" "interchangeably." Wong v. Regents of Univ. of California, 192 F.3d 807, 816 n.26 (9th Cir. 1999). Further, to the extent that a distinction does exist, whether a pool lift is a modification appears to be a question of fact because pool lifts do not necessarily involve physical changes to the premises. (See, e.g., Opp'n at 5 (listing examples of pool lifts) (Docket No. 13).)