I was questioning if this is from 1938. According to page 17 of Hake's Official Price Guide to Disney Collectibles the ©Disney wasn't used in 1938. ©Disney started in 1986 and is currently used. (According to the book, 1938 items would be some form of Walt Disney Enterprises if it had a copyright.)
A totally agree with you 1937 Fan. The most common imprint from 1937-38 is "W.D. Ent." The real key would be to identify the Genius Stationery Company and what their years of operation were. Unfortunately, I wasn't able to find anything online.