• Key pointChurch Names A church name is a valuable property right that is protected by the legal principle of unfair competition. Protection also is available under federal trademark law.
A federal court in Florida ruled that a local church's unauthorized use of the name "Seventh-Day Adventist" (and the acronym "SDA") could be prohibited on the ground that they violated the national Seventh-Day Adventist Church's trademark. In 1980 the Seventh-Day Adventist Church (the "national church") obtained a trademark registration for the name "Seventh-Day Adventist" with the United States Patent and Trademark Office. The trademark application indicated that the mark would be used in connection with several goods and services including religious publications, employee health care and benefit programs, medical insurance programs, educational services, film production, health care services, and church services. Several members of a Seventh-Day Adventist church in Florida left the church to form their own congregation (the "new church"). The new church used the names "Seventh-Day Adventist" and "SDA." The new church began a radio broadcast, and later sought to affiliate with a regional body of the national Seventh-Day Adventist Church. Denominational officials informed the church that it would not be allowed to affiliate until it discontinued radio broadcasts attacking the Catholic Church. The church refused to agree to this condition, and was unable to affiliate with the denomination. Nevertheless, the new church continued to use the name "Eternal Gospel Church of Seventh Day Adventists" on its church sign, in newspaper advertisements, fliers, billboards, bulletins, audio tape recordings, and on radio broadcasts. The new church is listed in the section of "Seventh-day Adventist Churches" in the local telephone directory. The national church sought a court order prohibiting the new church from using the name "Seventh-Day Adventist" or any confusingly similar name, or the acronym "SDA." A federal court issued the order, concluding that the new church had infringed upon the national church's trademark.