Well in the case of a professional web design company, making a website copmliant is the basics, and if they don't, it's either by lack or knowledge (which they can't claim to have - being professionals) or unwillingness (which is not forgiveable - being professionals).
What many seem to be missing is that Target has not been asked to make their site triple a compliant. We're not talking table-less CSS driven site with 5 different stylesheets to cater for all visual impairment. We are talking alt attribute and label tags! Thats webdesign 101.
Also many mentionned mom and pops businesses or owner managed website - but we're talking Target here - and so-called professional web designers or companies.
BTW I tried finding figures about target on their website. By accressing the about target with cookies disabled, I got trown into a infinite loop of
flash plugin checking > set cookie (not) > redirect > check cookie (not present so) > flash plugin checking > set cookie (not) > redirect > check cookie (not present so)[...].