Goodness, this thread again...
Okay, from what I understand "your opponent's" has the same qualifiers as "your", which requires both ownership and control. In the case of TToD, no, brigades on cards that your opponent either doesn't own or doesn't control don't count. If the card read "number of evil brigades in your opponent's territory", then that would work, because the cards would meet the qualification. But in the case of something like SWS, the player does not own the card, so it is not "your opponent's".
That make sense?