Kianfar

This case presents the question whether a civil court can decide this dispute over the rights to intellectual property of a religious order without violating the First Amendment. We conclude that it can, and accordingly reverse the district court’s dismissal of the complaint.

Maktab Tarighe Oveyssi Shah Maghsou-di, Inc. (“Shah Maghsoudi”), the corporate embodiment of an ancient Sufi Order, and its leader, Nader Angha, appeal the district court’s dismissal of their complaint against two former members of Shah Maghsoudi and the competing organization that they established. The two former members, Ali Kianfar and Nahid Kianfar, founded the International Association of Sufism, Inc. (“the Association”) after their expulsion from Shah Maghsoudi. Shah Maghsoudi and Angha allege that the Association is trading on Shah Maghsoudi’s goodwill by selling Shah Maghsoudi’s trademarked publications as the Association’s own and by employing a trademark which is a colorable imitation of Shah Maghsoudi’s registered trademark. Shah Maghsoudi and Angha assert claims of trademark infringement pursuant to 15 U.S.C. § 1114 , false designation of origin pursuant to 15 U.S.C. § 1125 (a), and supplemental…