13.    Target admits that, among other things, it owns and operates retail stores in California and the United States. Target further admits that, among other things, it operates a website located at www.target.com. Except as expressly admitted, Target denies the averments contained in paragraph 13.
14.    Target is without information or belief sufficient to admit or deny the averments of paragraph 14. Target denies the averments contained in paragraph 14 to the extent they assert legal conclusions to which no response is required.
15.    Target is without information or belief sufficient to admit or deny the averments of paragraph 15. Target denies the averments contained in paragraph 15 to the extent they assert legal conclusions to which no response is required.
16.    Target is without information or belief sufficient to admit or deny the averments of paragraph 16. Target further denies the averments contained in paragraph 16 to the extent they assert legal conclusions to which no response is required.
17.    Target denies the averments of paragraph 17, and further denies the averments contained in this paragraph to the extent they assert that the website located at www.target.com is inaccessible. Target denies the averments contained in paragraph 17 to the extent they assert legal conclusions to which no response is required.
18.    Target denies the averments contained in paragraph 18, and further denies the averments contained in this paragraph to the extent they assert legal conclusions to which no response is required.
19.    Target denies the averments contained in paragraph 19, and further denies the averments contained in this paragraph to the extent they assert legal conclusions to which no response is required.
20.    Target denies the averments contained in paragraph 20, and further denies the averments contained in this paragraph to the extent they assert legal conclusions to which no response is required.
21.    Target denies the averments contained in paragraph 21, and further denies the averments contained in this paragraph to the extent they assert legal conclusions to which no response is required.
22.    Answering paragraph 22, no response is required.
23.    Target admits that, among other things, it operates retail stores in California and the Untied States. Except as expressly admitted, Target denies the averments contained in paragraph 23.
24.    Target admits that, among other things, it operates a website located at www.target.com, and that words “Powered by Amazon.com” appear within the website. Except as expressly admitted, Target denies the averments contained in paragraph 24, and further denies these averments to the extent they assert legal conclusions to which no response is required.
25.    Target admits that, among other things, it operates a website located at www.target.com, and that visitors to the website may browse and purchase merchandise. Except as expressly admitted, Target denies the averments contained in paragraph 25, and further denies these averments to the extent they assert legal conclusions to which no response is required.
26.    Target admits that the website located at www.target.com contains a store locator, online pharmacy, online photoshop, weekly advertisements, coupons, online wedding and baby registries and coupons, as well as certain information regarding its REDcardsm program, certain community programs, employment opportunities, investor and company policies, and products for sale on the website itself. Except as expressly admitted, Target denies the averments contained in paragraph 26.
27.    Target denies the averments contained in paragraph 27.
28.    Target denies the averments contained in paragraph 28.
29.    Target is without knowledge or information sufficient to admit or deny the allegations of paragraph 29, which are vague and ambiguous.
30.    Target is without knowledge or information sufficient to admit or deny the allegations of paragraph 30.
31.    Target denies that “well-established guidelines” exist or apply to the website located at www.target.com. Target is without knowledge or information sufficient to admit or deny the remaining allegations of paragraph 31.
32.    Target denies the averments contained in paragraph 32.
33.    Target lacks information or belief sufficient to admit or deny that the descriptions and definitions contained within paragraph 33 are necessary, sufficient or complete, and denies these averments for that reason. Target further denies the remaining averments contained in paragraph 33.