Berdelle v. Carpentier

The plaintiffs applied for a corporate charter under the names of “Steel Company of Ohio,” “Steelco Manufacturing Company,” or “Steel Manufacturing Company.” The defendant, as Secretary of State of the State of Illinois, refused to issue the charter on the ground that the names are “deceptively similar” to the names “Ohio Steel Products Co.,” “Steel-Cor Manufacturing Company,” “Steel Doors Manufacturing Company” and “Steel-Parts Manufacturing Company,” previously registered corporations.

Upon refusal of the defendant to issue the charter, the plaintiffs filed petition in the circuit court of…