Upon information and belief, Defendant DISNEY CONSUMER
PRODUCTS (DCP) is the business segment of The Walt Disney
Company and its affiliates that extends the Disney brand to
merchandise ranging from apparel, toys and home décor to books
and magazines, foods and beverages, stationery, electronics and
animation artistry. DCP’s ultimate parent is The Walt DisneyCompany (“DISNEY”); DCP is doing business, inter alia, in the State
of Washington, specifically in this District, by acts including making
(or having made or authorizing to be made), offering and selling, and
or/offering and allowing to be sold, its product(s) (including the
accused product) via Internet sites including www.target.com, which
Internet site is accessible in the State of Washington, specifically in
this District.