RMK Financial Corporation is a California-based mortgage lender which also does business under the name Majestic Home Loans. RMK mailed print advertisements to more than 100,000 consumers in several states, using the names and logos of the Department of Veterans Affairs (VA) and the Federal Housing Administration (FHA) in a way that falsely implied that the advertisements were sent by the VA or FHA, or that the company or the advertised mortgage products were endorsed or sponsored by the VA or FHA. RMK sent its advertisements to tens of thousands of U. S. military service members and veterans, and other holders of VA-guaranteed mortgages. The company’s typical advertisement for VA mortgages featured the Department of Veterans Affairs seal and logo at the top of the page and described its loan products as part of a "distinctive program offered by the U. S. government." The ad instructed consumers to call the "VA Interest Rate Reduction Department" at a phone number that in f