Plaintiff RealNetworks, Inc. seeks a declaratory judgment that Defendant QSA Toolworks, LLC has no rights to the TCM HELIX marks, that any rights QSA has in the HELIX marks are junior to RealNetworks' rights in the HELIX marks, QSA is bound by the terms of the Consent Agreement as an assign and/or successor of TCM, and there is no likelihood of confusion with respect to each parties' use of HELIX for their respective goods and services.