March 31. On this date in 1941, the New York Supreme Court dismissed a court case brought by National Spiritual Assembly and Trustees of the Bahá'ís of the United States and Canada against Mirza Ahmad Sohrab for the use of the word "Bahá'í." The judge granted a motion to dismiss, stating that "the plaintiffs have no right to a monopoly of the name of a religion. The defendants, who purport to be members of the same religion, have an equal right to use the name of the religion..."

March 31. On this date in 1941, the New York Supreme Court dismissed a court case brought by National Spiritual Assembly and Trustees of the Bahá'ís of the United States and Canada against Mirza Ahmad Sohrab for the use of the word "Bahá'í." The judge granted a motion to dismiss, stating that "the plaintiffs have no right to a monopoly of the name of a religion. The defendants, who purport to be members of the same religion, have an equal right to use the name of the religion..."

Horace Holley, as a member of the National Spiritual Assembly and the New York Spiritual Assembly, had attempted to gain control of the "New History Society," which Ahmad Sohrab had founded in 1929 with Lewis Stuyvesant Chanler and his wife Julie, in order to propagate the Bahá'í Faith. Ahmad Sohrab had served as 'Abdu'l-Bahá's secretary and interpreter from 1912 to 1919. For example, aside from accompanying 'Abdu'l-Bahá during his tour of North America in 1912, on December 23, 1918, 'Abdu'l-Bahá sent Ahmad Sohrab to the United States to deliver the Tablets of the Divine Plan, a collection of 14 letters written between September 1916 and March 1917 by 'Abdu’l-Bahá to Bahá’ís in the United States and Canada. These collective letters, along with Bahá’u’lláh’s Tablet of Carmel and ‘Abdu’l-Bahá's Will and Testament were described by Shoghi Effendi as three of the "Charters" of the Bahá’í Faith.

The conflict resulted in Ahmad Sohrab and the Chanlers' being declared Covenant-breakers around 1939.

Despite the failed litigation, in 1951, Shoghi Effendi appointed Horace Holley a Hand of the Cause of God.

The Bahá'í Administrative Order has attempted, through the registration of trademarks and copyrights, to preserve for itself the exclusive right to utilize certain religious symbols and terminology. On August 28, 1934, the Most Great Name symbol was registered as a trademark (Trade-Mark 316,444). Similarly, the "Bahá'í" trademark (Trade-Mark 245,271) was registered with the Patent Office on August 7, 1928.

These trademarks have not prevented the use of the term "Bahá'í" by groups considered Covenant-breakers by the Bahá'í Administrative Order, as upheld in repeated failed litigation. For example, on May 8, 2005, the Orthodox Bahá'ís, listed as the Second International Bahá'í Council, won a legal case brought against them by the National Spiritual Assembly of the Bahá'ís of the United States before the World Intellectual Property Organization (see WIPO Case No. D2005-0214) for the use of the domain name uhj.net.