The corporation founded by William F. Cody, the actual Buffalo Bill, and two partners in 1913, which made a film of his wild west exploits, The Adventures of Buffalo Bill (1917), brought a suit in federal court in Colorado seeking an injunction to prevent the 1922 film serial from using the name "Buffalo Bill" and his likeness in any advertising.[2] Applying the law of unfair competition, the court dismissed the suit noting that the name, which at best had only a common law trademark, had acquired a secondary meaning regarding the American West which had lost its exclusivity from being used in several plays without challenge, and that the theater-going public could readily distinguish between the films.[3]