The National Spiritual Assembly of the Baha’is of the U.S.A. under the Hereditary Guardianship, Inc. v. National Spiritual Assembly of the Baha’is of the U.S.A., Inc.

Dist. Ct. did not err in denying request by movant (one branch of Baha'is church) for issuance of contempt sanctions against respondents (other branches of Baha'is church) where movant asserted that respondents violated terms of 1966 injunction that precluded former branch of Baha'is church (which is now disbanded) from using certain trademarked names. While certain members in respondent branches were key officers in enjoined branch, movant failed to show that instant respondents (who were non-parties in 1966 lawsuit) were in privity with enjoined branch. Moreover, movant failed to demonstrate that instant respondents were legally identified with enjoined branch so as to make terms of injunction binding on respondents where record did not show either that respondent branches were substantially similar to enjoined branch of Baha'is church, or that key officers from enjoined branch actually played any role in governing instant respondent branches, or that respondent branches were in fact operating in effect as enjoined branch.