Headlight Health sues Headlight Mental Healthcare, relying on intent-to-use priority from October 12, 2023: complaint allegations

What was filed

The complaint is Document 1, filed October 15, 2026, in the U.S. District Court for the District of Oregon, Portland Division. The case is Headlight Health, Inc. v. Headlight Mental Healthcare, PLLC and Headlight Mental Healthcare LLC, No. 3:26-cv-02262, and it includes a jury demand. It pleads three counts: federal trademark infringement under 15 U.S.C. § 1114; false designation of origin under 15 U.S.C. § 1125(a)(1)(A); and common-law trademark infringement and unfair competition under Oregon law. Counsel are Delfina S. Homen of Miller Nash LLP, with Todd Marabella and Samuel A. Kunzman of Goodwin Procter LLP (pro hac vice applications forthcoming).

What the complaint alleges

Headlight Health says it is a management services organization that licenses the HEADLIGHT mark to independent, physician-owned medical groups providing mental-health care, and that their use inures to its benefit under 15 U.S.C. § 1055. It says that on October 12, 2023, under its predecessor name SokyaHealth MSO, Inc., it filed intent-to-use Application Serial No. 98/220,317 for HEADLIGHT, which matured on June 23, 2026 into U.S. Reg. No. 8,315,599 for Class 44 mental health counseling, therapy, and psychotherapy services. It alleges that public use of the mark began no later than October 2024 and relies on the October 12, 2023 filing date for nationwide constructive-use priority under 15 U.S.C. § 1057(c).

It alleges that the Arizona defendant was formed December 18, 2023, that defendants' founder Matthew Laird wrote in a July 2, 2026 letter that use of HEADLIGHT began during the week of December 18, 2023, and that the Oregon defendant was formed December 16, 2024. It also points to a Better Business Bureau start date of December 15, 2023, a Facebook founding date of December 21, 2023, a January 8, 2024 registration of headlightmentalhealthcare.com, and an Arizona state registration for HEADLIGHT MENTAL HEALTHCARE listing a June 1, 2024 first-use date. It says defendants offer psychiatric evaluations, medication management, and related services, advertising a Portland office and telehealth throughout Oregon, that demand letters went out June 30 and July 24, 2026, and that defendants refused to stop. The prayer asks for preliminary and permanent injunctive relief against HEADLIGHT and HEADLIGHT MENTAL HEALTHCARE for mental-health services, an order to stop using and disable or redirect headlightmentalhealthcare.com, profits and damages under 15 U.S.C. § 1117(a), attorneys' fees, and other relief.