On information and belief, sometime prior to September, 2011,
Target.com began offering for sale a line of clothes arranged around
the popular Disney character named “Sharpay”, played by actress Ashley Tisdale; as part of a promotion of the Disney movie
“Sharpay’s Fabulous Adventure” Notably, the offering included the
accused product, i.e. a “D-Signed" Sharpay Girls Short-Sleeve Dogs
Graphic Tee” (Shown at Exhibit 7).
Comparison of Copyrighted Work with Accused Shirt