Collins

Background 26 Plaintiff Rick Collins is a veteran who founded a non-profit organization, Veterans 27 360, in 2012. The organization provides counseling, advocacy, and mentorship to active 28 duty personnel, veterans, and their families. (Doc. No. 1 ¶ 5.) When forming this organization, Mr. Collins created the trademarks “Veterans 360” and “Vets 360” for use by his organization in providing support services to veterans. (Id. at ¶¶ 7–8.) Mr. Collins registered the “Veterans 360” mark on July 5, 2016 with the U.S. Patent and Trademark Office (“PTO”), Registration No. 4,991,432. (Doc. No. 16-6.) On January 15, 2019, Mr. Collins registered the “Vets 360” mark with the PTO, Registration No. 5,654,087. (Doc. No. 16-7.) In April 2018, Defendant United States Department of Veteran Affairs rolled out a web-based platform to provide veteran’s services, naming the platform “Veteran 360” and “Vet 360.” (Id. ¶ 9; Doc. No. 17 at 6.) On May 26, 2018, Plaintiffs wrote a letter to Defendant to notify Defendant that it was infringing Plaintiffs’ marks. (Doc. No. 16-8.) On June 26, 2018, Plaintiffs wrote a second letter to Defendant, informing…