Applicant is the owner of the marks PURE (Reg. No. 7803910) and PURE + Design (Reg. No. 7803934). Applicant’s date of first use in commerce for each mark is May 2013. Applicant is currently a party to Cancellation No. 92089704 against Crothers Cooling and Heating, Inc. of Naples, Florida. Crothers’ applications were each filed after Applicant began using its marks in commerce. As the trademark dispute between the parties involves determination of concurrent rights with geographic limits, which can only be done in a concurrent use proceeding, the present application is intended to provide grounds for converting the cancellation proceeding into a concurrent use proceeding.