• The Church of Jesus Christ of Latter-day Saints
  • Key facts
  • Institutional description in the complaint
  • The Church’s claims against Mormon Stories
  • The Church’s asserted marks and copyrights
  • Pre-suit contacts and the disclaimer request
  • The Church’s position that the suit is not about criticism
  • The Church’s legal arguments on Rogers and laches
  • The 2018 retirement of the term ‘Mormon’
  • Allegations about the Church’s USPTO filings
  • Alleged prior knowledge of the podcast
  • Amicus participation against the Church’s position
  • The intervention motion and the Church’s opposition
  • Church leadership statements on doubt and podcasts
  • Debate over whether the Church is Christian
  • A personal account of the Church
  • Where sources disagree
    • Whether the Church holds enforceable rights in the term ‘Mormon’
    • Whether consumers are actually confused about Mormon Stories’ affiliation with the Church
    • Whether the lawsuit is aimed at suppressing criticism
    • Whether the Church’s 20-year delay bars its claims
    • Whether the Rogers test should shield the podcast title
    • Whether the intervention motion raises justiciable questions about the terms’ pre-institutional history
    • Whether the Church’s requested disclaimer was a reasonable remedy
  • What this corpus does not establish

§The Church of Jesus Christ of Latter-day Saints

The Church of Jesus Christ of Latter-day Saints appears in this corpus principally as the plaintiff — together with Intellectual Reserve, Inc. — in a federal trademark and copyright suit filed in the U.S. District Court for the District of Utah against the Open Stories Foundation and John P. Dehlin over the MORMON STORIES podcast (Case No. 2:26-cv-00321-JCB). The corpus consists mostly of filings in that case (the complaint, the answer and counterclaims, a motion to dismiss and the opposition, a non-party motion to intervene and the briefing around it, and amicus briefs from the ACLU of Utah and the Electronic Frontier Foundation), together with news coverage, commentary videos, and podcast episodes discussing the Church. Sources describe the Church both as a worldwide religious institution founded in 1830 and as a trademark owner asserting a “family of marks” incorporating the term MORMON, and they disagree sharply about whether the Church retains rights in that term after its 2018 campaign to stop using it. A separate strand of the corpus records personal and doctrinal discussion of the Church — a deconversion narrative, a debate over whether Mormons are Christians, and an address by Church President Dallin H. Oaks.

§Key facts

Each entry is a captured claim; the quote is its verification.

• The public associates the term MORMON with the Church, which has used MORMON-inclusive marks for nearly 200 years. — storage.courtlistener.com

  “the public associates the term MORMON with The Church of Jesus Christ of Latter-day Saints, which has used the mark MORMON and other names and marks incorporating the term MORMON since its founding nearly 200 years ago.”

• Defendants’ use of Church trademarks and copyrighted materials causes and will continue to cause confusion about affiliation with the Church. — storage.courtlistener.com

  “Defendants’ use of Church trademarks and copyrighted materials has caused and will continue to cause individuals to be confused and access Defendants’ content mistakenly believing it comes from or is affiliated with or endorsed by the Church.”

• Plaintiffs simultaneously claim the terms denote historical/religious narrative and also claim exclusive trademark association, creating a dual characterization. — storage.courtlistener.com

  “Plaintiffs simultaneously assert that these terms denote a historical narrative and religious record involving ancient peoples and a historical figure while also claiming they are exclusive marks uniquely associated with Plaintiffs.”

• President Nelson declared ‘Mormon’ would no longer be used as an identifier and condemned its use. — storage.courtlistener.com

  “Church President at the time, Russell M. Nelson, declared that the Church would no longer use “Mormon” as an identifier, declared that “Mormon” was simply an “adjective,” and condemned its use as antithetical to the Church’s religious teachings and beliefs.”

• In 2018 the Church publicly abandoned use of the word ‘Mormon’ as a brand identifier. — storage.courtlistener.com

  “Instead, in 2018, the Church publicly and expressly abandoned (to the extent it owned any rights in “Mormon,” which Defendants do not concede) the very word “Mormon” that it now claims ownership and control of and sues to protect.”

• The lawsuit is about brand confusion, because multiple elements of Mormon Stories’ branding taken together have led people to be confused about whether the critical podcast comes from the church. — youtube.com

  “It’s always been about brand confusion because many elements of the Mormon Stories branding collectively have caused people to be confused about whether this critical podcast is coming from the church.”

• The Church was founded in the United States in 1830. — storage.courtlistener.com

  “The Church of Jesus Christ of Latter-day Saints is a worldwide faith, founded in the United States in 1830.”

• The public has long called the Church the ‘Mormon Church’ and its members ‘Mormons.’ — storage.courtlistener.com

  “the public has long referred to and recognized the Church as the “Mormon Church” and its members as “Mormons.””

• The Church attempted pre-suit resolution before filing the complaint. — storage.courtlistener.com

  “Before filing this Complaint, the Church notified Defendants of its concerns and attempted to work with Defendants in making changes to mitigate the confusion they have caused and are likely to cause in the future.”

• When approached, Defendants made some changes but refused to take basic steps to reduce confusion. — storage.courtlistener.com

  “When the Church approached Defendants about their infringement of the Church’s intellectual property rights, they agreed to make some changes but ultimately would not agree to take basic actions necessary to lessen the confusion caused by Defendants’ infringements.”

• The Church states it does not seek to control the podcast’s content, only to prevent trademark-based confusion. — storage.courtlistener.com

  “The Church does not seek, in any way, to influence the content of Defendants’ podcast, but Defendants should not be allowed to use the Church’s trademarks or other Church intellectual property to cause confusion as to the source, affiliation, connection, endorsement, or authorization of Defendants’ podcast and other content.”

• The Church argues it needs to protect its marks so members can distinguish authorized from unauthorized materials. — storage.courtlistener.com

  “In order to fulfill its religious mission, the Church must ensure its millions of members and others seeking information about the Church can identify, recognize, and trust materials created or authorized by the Church, and distinguish them from information provided by other sources.”

• Plaintiffs have used MORMON-related marks continuously in commerce for nearly 200 years. — storage.courtlistener.com

  “Plaintiffs have continuously used in commerce marks incorporating the term MORMON for nearly 200 years.”

• Plaintiffs allege Defendants’ acts constitute federal trademark infringement under the Lanham Act (Count I). — storage.courtlistener.com

  “The acts of Defendants complained of herein constitute infringement of Plaintiffs’ federally registered trademarks in violation of Section 32 of the Lanham Act, 15 U.S.C. § 1114.”

• The Church waited 20 years after Defendants began using the mark before suing. — storage.courtlistener.com

  “Plaintiffs’ Complaint correctly alleges that Defendants began using the MORMON STORIES title for their podcast in 2005, twenty years before the Church took the present enforcement actions.”

• The Church knew or should have known about the podcast for decades, triggering a laches presumption. — storage.courtlistener.com

  “Defendants’ widespread, open use of MORMON STORIES for decades leaves no room for an inference other than the Church having knowledge of the accused actions—or at a minimum constructive knowledge—long before it filed this case, thus triggering a presumption of laches”

• The Church publicly responded to Dehlin’s podcast comments in 2015, evidencing its awareness of the podcast a decade before suing. — storage.courtlistener.com

  “the Church itself issued a press release in 2015 entitled “Church Responds to John Dehlin’s Public Comments” referring to Dehlin and the opinions he expresses on his podcast, over a decade before filing the present lawsuit.”

• The Church itself has said ‘Mormon’ is merely a nickname for its members, not exclusively tied to the Church as a trademark. — storage.courtlistener.com

  “the Church itself has publicly declared that “Mormon” is only a “nickname” for members”

• Defendants argue no entity, including the Church, legally controls the word ‘Mormon’. — storage.courtlistener.com

  “No single source, including the Church, has the legal right to control the use of “Mormon.””

• The Church renamed the historic Mormon Tabernacle Choir to remove ‘Mormon’. — storage.courtlistener.com

  “Renaming the Mormon Tabernacle Choir (a 150-year-old institution) to the Tabernacle Choir at Temple Square;”

• The Church issued a still-active style guide instructing media to stop using ‘Mormon’ as the Church’s name. — storage.courtlistener.com

  “Issuing a Style Guide that is still in force today, explaining that “Mormon” is simply an “adjective” or “proper name” (not a brand), eliminating all use of the term “Mormon” as an identifier of the Church, and instructing the media and public to stop calling the Church “Mormon” and to stop referring to its members as “Mormons.””

• The Church allegedly filed false sworn declarations to USPTO about continued use of ‘Mormon’ marks while abandoning them publicly. — storage.courtlistener.com

  “Even as the Church spent years publicly dismantling every trace of “Mormon” from its branding, it simultaneously submitted sworn declarations to the USPTO falsely representing the true nature of the Church’s ongoing trademark use, or lack thereof, regarding the term “Mormon.””

• USPTO previously found ‘Mormon’ generic, comparing it to ‘Catholic’. — storage.courtlistener.com

  “The USPTO and Trademark Trial and Appeal Board concluded “Mormon” was generic in connection with Ser. No. 78/161,091, explaining that “Mormon” “is a word similar to ‘CATHOLIC’” as a generic term denoting a religion.”

• Defendants allege the lawsuit’s true motive is to silence or limit reach of Dehlin’s content, not to prevent confusion. — storage.courtlistener.com

  “the present lawsuit is not motivated by a genuine concern over source affiliation confusion, but instead by a desire to silence, or at a minimum limit the reach of, the

content, opinions, and viewpoints shared on the MORMON STORIES podcast and its affiliate sites.”

• Defendants argue there is no actual likelihood of consumer confusion, even by the Church’s own evidence. — storage.courtlistener.com

  “Even as evidenced by the Church’s own asserted examples of alleged consumer confusion in the Complaint, no consumers are actually or likely to be confused as to the source of the MORMON STORIES podcast.”

• Defendants assert the Church has no valid trademark rights in ‘Mormon’ due to genericness and abandonment. — storage.courtlistener.com

  “Plaintiffs do not own trademark rights in the name “Mormon” because the word is generic, and to the extent any rights could be acquired in the name “Mormon,” which Defendants do not concede, Plaintiffs expressly abandoned any such rights.”

• Defendants assert laches due to the Church’s two-decade delay in bringing claims. — storage.courtlistener.com

  “Plaintiffs’ trademark infringement claims are unenforceable against Defendants or barred, in whole or in part, due to the equitable defense of laches. Plaintiffs unreasonably delayed for two decades in asserting their claims for trademark infringement against Defendants’ use of MORMON STORIES as the title for their 20-year-old podcast, and Defendants have been materially prejudiced by Plaintiffs’ inexcusable delay.”

• High-level Church officials knew of the podcast for two decades without raising IP concerns. — storage.courtlistener.com

  “Since the podcast’s inception, officials at the highest level of the Church have been aware of Dehlin and MORMON STORIES podcast without once suggesting any intellectual property concerns regarding the name of the podcast, its logos, or any aspect of its branding.”

• The Church first raised IP concerns only in November 2025, decades after the podcast began. — storage.courtlistener.com

  “In November 2025, more than twenty years after the MORMON STORIES podcast launched and nearly three years after Defendants adopted the blue logo of which the Church complains, the Church raised trademark or copyright concerns to Defendants for the first time.”

• Defendants promptly and voluntarily cooperated with the Church’s requests despite disagreeing with the claims. — storage.courtlistener.com

  “Defendants responded within twenty-four hours voluntarily making numerous changes in the spirit of good faith cooperation, despite believing that the Church’s claims were unfounded.”

• Defendants allege the Church responded to their cooperation with a lawsuit and a misleading press release. — storage.courtlistener.com

  “The Church’s response to Defendants’ gestures of extraordinary and voluntary amenability was to file this lawsuit and issue a false and misleading press release depicting Defendants as uncooperative and deceptive.”

• Defendants allege the lawsuit itself, regardless of merit, could silence them and chill speech given the resource imbalance. — storage.courtlistener.com

  “Because the Church is a multi-billion-dollar religious institution with unlimited resources to wield in its enforcement efforts, the very existence of the present lawsuit alone (despite the merits thereof) has the potential to ultimately silence Defendants through attrition (which may possibly be by design) and thereby create a chilling effect for other Church critics and questioners who, like Defendants, engage in constitutionally protected speech about Mormonism.”

• The terms in dispute are historically/religiously referential, not merely commercial identifiers, and predate the Church’s founding. — storage.courtlistener.com

  “The terms “Mormon” and “Book of Mormon” are not merely commercial identifiers. They are historically and religiously referential terms that implicate theology, historiography, and Indigenous custodial histories that predate the institutional formation of the claimant.”

• The Church’s complaint claims these terms are exclusive institutional identifiers and a family of marks. — storage.courtlistener.com

  “Plaintiff’s Complaint expressly asserts that the terms “MORMON” and “BOOK OF MORMON” function as exclusive institutional identifiers of the Plaintiff and constitute a family of marks denoting origin, sponsorship, and authorization by the Church.”

• The LDS Church’s own Gospel Topics Essay states that members unequivocally affirm themselves to be Christian. — youtube.com

  “members of the Church of Jesus Christ of Latter-day Saints unequivocally affirm themselves to be Christian.”

• Keira credits the LDS Church and its community with saving her from an abusive childhood. — youtube.com

  “I think that it’s fair to say that the church saved me from a really horrible, abusive family.”

§Institutional description in the complaint

According to the complaint filed by Intellectual Reserve, Inc. and the Church, the Church is “a worldwide faith, founded in the United States in 1830,” whose membership has “grown to over 17 million members with over 30,000 congregations in more than 160 countries and territories worldwide.” The complaint states that “the public has long referred to and recognized the Church as the ‘Mormon Church’ and its members as ‘Mormons.’” The Salt Lake Tribune’s Mormon Land episode describes the plaintiff as “the global faith of 17.8 million members.”

“the public has long referred to and recognized the Church as the “Mormon Church” and its members as “Mormons.”” (source b7842aa7…)

“could lead some listeners to believe the podcast is affiliated with the global faith of 17.8 million members” (source 22a50eb2…)

§The Church’s claims against Mormon Stories

The complaint alleges that Open Stories Foundation and John Dehlin “operate a podcast under the name and mark MORMON STORIES” and that “the public associates the term MORMON with The Church of Jesus Christ of Latter-day Saints, which has used the mark MORMON and other names and marks incorporating the term MORMON since its founding nearly 200 years ago.” It asserts that the defendants’ use “has caused and will continue to cause individuals to be confused and access Defendants’ content mistakenly believing it comes from or is affiliated with or endorsed by the Church.” Beyond the word itself, the Church points to a “blue MORMON STORIES logo with a light-rays design prominently used by the Church,” to the Christus Symbol, and to copyrighted images. The Church frames its interest in religious-mission terms: it says it “must ensure its millions of members and others seeking information about the Church can identify, recognize, and trust materials created or authorized by the Church.” The complaint brings claims under Section 32 and Section 43(a) of the Lanham Act, Utah trademark law, and 17 U.S.C. § 501. According to a Salt Lake Tribune-adjacent commentary piece, the suit was filed “On April 17, 2026” and “brings four counts in the U.S. District Court for the District of Utah: trademark infringement, false designation of origin under the Lanham Act, Utah trademark infringement, and copyright infringement.”

“the public associates the term MORMON with The Church of Jesus Christ of Latter-day Saints, which has used the mark MORMON and other names and marks incorporating the term MORMON since its founding nearly 200 years ago.” (source b7842aa7…)

“Defendants’ use of Church trademarks and copyrighted materials has caused and will continue to cause individuals to be confused and access Defendants’ content mistakenly believing it comes from or is affiliated with or endorsed by the Church.” (source b7842aa7…)

“In order to fulfill its religious mission, the Church must ensure its millions of members and others seeking information about the Church can identify, recognize, and trust materials created or authorized by the Church, and distinguish them from information provided by other sources.” (source b7842aa7…)

“The acts of Defendants complained of herein constitute infringement of Plaintiffs’ federally registered trademarks in violation of Section 32 of the Lanham Act, 15 U.S.C. § 1114.” (source b7842aa7…)

“brings four counts in the U.S. District Court for the District of Utah: trademark infringement, false designation of origin under the Lanham Act, Utah trademark infringement, and copyright infringement. (Case No. 2:26-cv-00321-JCB.)” (source a5453cb3…)

§The Church’s asserted marks and copyrights

The complaint states that “Plaintiff Intellectual Reserve, Inc. owns many U.S. trademark registrations for certain of Plaintiffs’ Marks,” that certain registrations “have achieved incontestable status under 15 U.S.C. § 1065,” and that the MORMON Marks “constitute a family of marks.” It also identifies a “Light-Rays Design mark” used “Since at least as early as May 2016,” and the Christus Symbol, which it says “is used as the Church’s official visual identifier, including for official media, literature, news, and events of the Church.” The Church further asserts “valid copyrights in the images shown directly below and in Exhibit 2 (the “Copyrighted Church Images”).”

“Thus, the MORMON Marks constitute a family of marks.” (source b7842aa7…)

“Since at least as early as May 2016, Plaintiffs have broadly and prominently used in commerce a distinctive Light-Rays Design mark” (source b7842aa7…)

“Plaintiffs also own valid copyrights in the images shown directly below and in” (source b7842aa7…)

“Federal” (source b7842aa7…)

§Pre-suit contacts and the disclaimer request

According to the complaint, “When the Church approached Defendants about their infringement of the Church’s intellectual property rights, they agreed to make some changes but ultimately would not agree to take basic actions necessary to lessen the confusion,” and specifically that “Defendants refused to include a simple statement, either verbal or written, at the beginning of podcast episodes acknowledging that Mormon Stories is not affiliated with the Church.” A commentary piece in the corpus, “The ‘Unreasonable Demand’ That Got Mormon Stories Sued,” characterizes the same request as modest, saying “the Church didn’t ask them to shut down or influence the content of the podcast.” The defendants’ answer gives a different account, stating that “Defendants responded within twenty-four hours voluntarily making numerous changes in the spirit of good faith cooperation, despite believing that the Church’s claims were unfounded,” and that “The Church’s response to Defendants’ gestures of extraordinary and voluntary amenability was to file this lawsuit and issue a false and misleading press release depicting Defendants as uncooperative and deceptive.”

“Defendants refused to include a simple statement, either verbal or written, at the” (source b7842aa7…)

“the Church didn’t ask them to shut down or influence the content of the podcast” (source 510d476c…)

“Defendants responded within twenty-four hours voluntarily making numerous changes in the spirit of good faith cooperation, despite believing that the Church’s claims were unfounded.” (source 58d50410…)

“The Church’s response to Defendants’ gestures of extraordinary and voluntary amenability was to file this lawsuit and issue a false and misleading press release depicting Defendants as uncooperative and deceptive.” (source 58d50410…)

§The Church’s position that the suit is not about criticism

In its opposition to the motion to dismiss, the Church states: “This case is not about silencing criticism. The Church’s claims do not target the content of Defendants’ speech at all. Nor is it about ownership or control of the word Mormon.” The brief adds that “The First Amendment protects Defendants’ speech; it does not license them to appropriate the Church’s marks and images,” and clarifies that “Plaintiffs are not arguing that Defendants’ use of the word ‘Mormon’ standing alone is a source identifier.” FOX 13 reported the Church’s statement that “this case is not about preventing people from using the word Mormon. It concerns the use of Church-protected names, images, and design elements, which in the collective create confusion when it comes to knowing whether the content is affiliated with the Church.” A commentary article aligned with this framing writes that “It’s always been about brand confusion because many elements of the Mormon Stories branding collectively have caused people to be confused about whether this critical podcast is coming from the church.”

“This case is not about silencing criticism. The Church’s claims do not target the content of Defendants’ speech at all. Nor is it about ownership or control of the word Mormon.” (source 53abe0b4…)

“Plaintiffs are not arguing that Defendants’ use of the word “Mormon” standing alone is a source identifier.” (source 53abe0b4…)

“this case is not about preventing people from using the word Mormon. It concerns the use of Church-protected names, images, and design elements, which in the collective create confusion when it comes to knowing whether the content is affiliated with the Church.” (source 4f05052a…)

“It’s always been about brand confusion because many elements of the Mormon Stories branding collectively have caused people to be confused about whether this critical podcast is coming from the church.” (source 06846e94…)

§The Church’s legal arguments on Rogers and laches

Opposing dismissal, the Church argues that under Jack Daniel’s, “Because Defendants clearly use the contested marks as trademarks, they cannot rely on Rogers or any other test to ‘escape from the likelihood-of-confusion inquiry and [as] a shortcut to dismissal.’” It contends “Under Jack Daniel’s, the inquiry is not whether the accused use is a title of an expressive work but whether the use functions as a source identifier.” On the delay defense, the Church argues “Laches is a fact-intensive affirmative defense that generally cannot be resolved on a motion to dismiss,” invokes progressive encroachment — “The doctrine of progressive encroachment excuses delay, allowing a plaintiff to wait to bring an action until the likelihood of confusion looms large” — and says it “intends to prove that Defendants’ infringement became increasingly more blatant over time until the Church had no choice but to take action to protect its intellectual property.”

“Under Jack Daniel’s, the inquiry is not whether the accused use is a title of an expressive work but whether the use functions as a source identifier.” (source 53abe0b4…)

“Laches is a fact-intensive affirmative defense that generally cannot be resolved on a motion to dismiss.” (source 53abe0b4…)

“The Church intends to prove that Defendants’ infringement became increasingly more blatant over time until the Church had no choice but to take action to protect its intellectual property.” (source 53abe0b4…)

““The doctrine of progressive encroachment excuses delay, allowing a plaintiff to wait to bring an action until the likelihood of confusion looms large.”” (source 53abe0b4…)

§The 2018 retirement of the term ‘Mormon’

The defendants’ answer and counterclaims describe a 2018 institutional campaign to abandon the word. It states that “in 2018, the Church publicly and expressly abandoned (to the extent it owned any rights in ‘Mormon,’ which Defendants do not concede) the very word ‘Mormon’ that it now claims ownership and control of and sues to protect,” and that then-President “Russell M. Nelson, declared that the Church would no longer use ‘Mormon’ as an identifier, declared that ‘Mormon’ was simply an ‘adjective,’ and condemned its use as antithetical to the Church’s religious teachings and beliefs.” Enumerated steps include “Renaming the Mormon Tabernacle Choir (a 150-year-old institution) to the Tabernacle Choir at Temple Square.” On the Mormon Land podcast, EFF attorney Cara Gagliano described the same period: “this is honestly one of the clearest cases of that I’ve ever seen, where, you know, the church over a period of years systematically was changing the names of like all its apps, all its programming, even the Mormon Tabernacle Choir.” A commentary video observes that “This same church has spent years telling people, don’t call us Mormon anymore.”

“Instead, in 2018, the Church publicly and expressly abandoned (to the extent it owned any rights in “Mormon,” which Defendants do not concede) the very word “Mormon” that it now claims ownership and control of and sues to protect.” (source 58d50410…)

“Church President at the time, Russell M. Nelson, declared that the Church would no longer use “Mormon” as an identifier, declared that “Mormon” was simply an “adjective,” and condemned its use as antithetical to the Church’s religious teachings and beliefs.” (source 58d50410…)

“this is honestly one of the clearest cases of that I’ve ever seen, where, you know, the church over a period of years systematically was changing the names of like all its apps, all its programming, even the Mormon Tabernacle Choir” (source 22a50eb2…)

“This same church has spent years telling people, don’t call us Mormon anymore.” (source da5daec1…)

§Allegations about the Church’s USPTO filings

The defendants’ counterclaims allege that “Even as the Church spent years publicly dismantling every trace of ‘Mormon’ from its branding, it simultaneously submitted sworn declarations to the USPTO falsely representing the true nature of the Church’s ongoing trademark use.” They cite a March 30, 2022 declaration for the MORMON CHANNEL registration, a January 21, 2022 declaration for MORMON MESSAGES, and March 1, 2024 declarations for the choir marks, alleging the last were supported by a specimen showing “an alteration of the name of the choir.” The counterclaims also state that in 2002 Intellectual Reserve applied to register “Mormon” and “The examiner refused registration finding that ‘Mormon’ was generic,” and that the USPTO and TTAB explained that “Mormon” “is a word similar to ‘CATHOLIC’” as a generic term denoting a religion. On Mormon Land, Gagliano made a related observation about the Church’s specimens: “they submitted what was supposed to be proof that they were still using it and it would be like screenshots of YouTube videos that were uploaded in 2013.” The corpus does not contain a Church response to these specific allegations.

“Even as the Church spent years publicly dismantling every trace of “Mormon” from its branding, it simultaneously submitted sworn declarations to the USPTO falsely representing the true nature of the Church’s ongoing trademark use, or lack thereof, regarding the term “Mormon.”” (source 58d50410…)

“The USPTO and Trademark Trial and Appeal Board concluded “Mormon” was generic in connection with Ser. No. 78/161,091, explaining that “Mormon” “is a word similar to ‘CATHOLIC’” as a generic term denoting a religion.” (source 58d50410…)

“the declarants submitted a specimen showing a product page from the Deseret Book website” (source 58d50410…)

“they submitted what was supposed to be proof that they were still using it and it would be like screenshots of YouTube videos that were uploaded in 2013” (source 22a50eb2…)

§Alleged prior knowledge of the podcast

The defendants assert that Church leaders knew of Mormon Stories for two decades: “Since the podcast’s inception, officials at the highest level of the Church have been aware of Dehlin and MORMON STORIES podcast without once suggesting any intellectual property concerns regarding the name of the podcast, its logos, or any aspect of its branding.” They describe a June 2009 lunch with “Elder Jefferey R. Holland from the Church’s Quorum of the Twelve Apostles,” at which, they allege, “At no time during the June 2009 lunch did Elder Holland ever ask Dehlin to stop the podcast.” The motion to dismiss adds that “the Church itself issued a press release in 2015 entitled ‘Church Responds to John Dehlin’s Public Comments’ referring to Dehlin and the opinions he expresses on his podcast, over a decade before filing the present lawsuit.” The answer states that “In November 2025, more than twenty years after the MORMON STORIES podcast launched and nearly three years after Defendants adopted the blue logo of which the Church complains, the Church raised trademark or copyright concerns to Defendants for the first time.”

“Since the podcast’s inception, officials at the highest level of the Church have been aware of Dehlin and MORMON STORIES podcast without once suggesting any intellectual property concerns regarding the name of the podcast, its logos, or any aspect of its branding.” (source 58d50410…)

“At no time during the June 2009 lunch did Elder Holland ever ask Dehlin to stop the podcast.” (source 58d50410…)

“the Church itself issued a press release in 2015 entitled “Church Responds to John Dehlin’s Public Comments” referring to Dehlin and the opinions he expresses on his podcast, over a decade before filing the present lawsuit.” (source a8ce7c13…)

“In November 2025, more than twenty years after the MORMON STORIES podcast launched and nearly three years after Defendants adopted the blue logo of which the Church complains, the Church raised trademark or copyright concerns to Defendants for the first time.” (source 58d50410…)

§Amicus participation against the Church’s position

The ACLU of Utah filed an amicus brief arguing that “The word ‘Mormon’ is not a source identifier. It is a term that describes an entire ethnoreligious culture, tradition, and people, many of whom are not members of the Church of Jesus Christ of Latter-day Saints (‘LDS Church’),” and urging the court to “reject this attempt to weaponize trademark enforcement to suppress speech and criticism, and grant Defendants’ Motion to Dismiss.” The Electronic Frontier Foundation, which says it “has provided legal counsel to individuals and organizations that have faced legal threats for using the term ‘Mormon’,” argues the Rogers test should apply and that “Plaintiffs have a history of this kind of trademark abuse. In 2016, for example, they threatened the Mormon Mental Health Association.” A commentary video reported that “an amicus brief was filed by two really important organizations in support of John DeLynn saying this needs to be dismissed.”

“The word “Mormon” is not a source identifier. It is a term that describes an entire ethnoreligious culture, tradition, and people, many of whom are not members of the Church of Jesus Christ of Latter-day Saints (“LDS Church”).” (source 40745369…)

“Amicus Curiae respectfully submits that the Court should reject this attempt to weaponize trademark enforcement to suppress speech and criticism, and grant Defendants’ Motion to Dismiss (ECF No. 41).” (source 40745369…)

“For several years, EFF has provided legal counsel to individuals and organizations that have faced legal threats for using the term “Mormon” while engaging in, or providing, commentary and discussion related to the Church of Jesus Christ of Latter-Day Saints (the “LDS Church”).” (source a846d3f8…)

“Unfortunately, Plaintiffs have a history of this kind of trademark abuse. In 2016, for example, they threatened the Mormon Mental Health Association” (source e2f4e0fe…)

“Just on Friday an amicus brief was filed by two really important organizations in support of John DeLynn saying this needs to be dismissed” (source 9a1c55b8…)

§The intervention motion and the Church’s opposition

A non-party, David Scott Taylor, appearing as “Ogimaa Songab Midegah Ogichidaa Zozep Anishaa, Traditional Chief (Ogimaa) of the Adik Doodem (Caribou Clan),” moved to intervene or file an amicus brief, arguing that the Church’s enforcement theory “would require the Court to treat historically and religiously referential terminology as proprietary commercial assets, despite their intersection with Indigenous history and faith that predates the Plaintiff institution.” The Church opposed, arguing that the movant “identifies no legally cognizable interest of his own that will be adjudicated in this action,” that “This case concerns only whether Defendants have violated the Lanham Act,” and that “to the extent that Movant’s arguments would require this Court to determine whether The Book of Mormon is a historical record and whether Mormon was a historical person, Movant’s position cannot be adjudicated in a secular court.” The Church’s brief states that it “recognizes that this Court is prohibited from addressing that issue, just as it is prohibited from determining ‘whether Jesus Christ walked on water or Muhammed communed with the archangel Gabriel.’” A separate procedural filing records that the Church sought and obtained an extension of its deadline to respond to the intervention motion “from May 22, 2026, to May 29, 2026.”

“It is brought because the relief sought in this action-the application of trademark doctrines to restrict use of the terms “MORMON” and “BOOK OF MORMON” -would require the Court to treat historically and religiously referential terminology as proprietary commercial assets, despite their intersection with Indigenous history and faith that predates the Plaintiff institution.” (source def0acff…)

“This case concerns only whether Defendants have violated the Lanham Act. Any judgment will not affect Movant’s asserted concerns.” (source 9b94c24e…)

“to the extent that Movant’s arguments would require this Court to determine whether The Book of Mormon is a historical record and whether Mormon was a historical person, Movant’s position cannot be adjudicated in a secular court” (source 9b94c24e…)

“Plaintiffs Intellectual Reserve, Inc. and The Church of Jesus Christ of Latter-day Saints (together the “Church”) respectfully move the Court to extend their deadline to file their response in opposition to non-party David Scott Taylor’s Motion to Intervene or, in the Alternative, for Leave to File Amicus Curiae Brief (Dkt. No. 17) (the “Motion to Intervene”) from May 22, 2026, to May 29, 2026.” (source 7a1d19ec…)

§Church leadership statements on doubt and podcasts

The corpus includes an address by Dallin H. Oaks, described as his first BYU address as president of the Church, in which he says “Whatever those doubts, the way to overcome them is to get closer to our Savior Jesus Christ,” acknowledges that “Even active members may sometimes have concerns about some historical, doctrinal, or social issues connected with the Church,” and warns that “An abundance of speculation and false information in podcasts and on social media surrounds us.” He also states that “Those of diminishing faith and activity in the restored Church are a major source of concern to your prophet leaders.” The defendants’ answer places a talk by President Oaks in the litigation timeline, alleging “President Oaks gave a talk on February 10, 2026, warning Church members about the dangers of podcasts.”

“Whatever those doubts, the way to overcome them is to get closer to our Savior Jesus Christ. Again and again, He has taught us that He is the way.” (source 0dc10b2e…)

“An abundance of speculation and false information in podcasts and on social media surrounds us.” (source 0dc10b2e…)

“Those of diminishing faith and activity in the restored Church are a major source of concern to your prophet leaders.” (source 0dc10b2e…)

“President Oaks gave a talk on February 10, 2026, warning Church members about the dangers of podcasts” (source 58d50410…)

§Debate over whether the Church is Christian

A live call-in episode in the corpus canvasses whether Mormons are Christians. It quotes a Church Gospel Topics source stating that “members of the Church of Jesus Christ of Latter-day Saints unequivocally affirm themselves to be Christian,” while a panelist argues “Mormonism has always held itself out as being the one true Christian sect.” Another participant states that under LDS doctrine “no Christian, no non-Mormon Christian baptism counts in heaven according to Mormons.” The episode reports audience polling that “65% of people of our audience who identifies as Christian do not consider Mormons to be Christian,” while “a majority, um, of our non-Christian audience, 54%, Do consider Mormons to be Christian.” Callers cited doctrinal differences including “the difference in the Trinity.”

“members of the Church of Jesus Christ of Latter-day Saints unequivocally affirm themselves to be Christian.” (source 3d046bac…)

“Mormonism has always held itself out as being the one true Christian sect.” (source 3d046bac…)

“no Christian, no non-Mormon Christian baptism counts in heaven according to Mormons.” (source 3d046bac…)

“65% of people of our audience who identifies as Christian do not consider Mormons to be Christian” (source 3d046bac…)

§A personal account of the Church

One Mormon Stories episode in the corpus features Keira Shae, who describes the Church in both rescuing and harmful terms. She says “I think that it’s fair to say that the church saved me from a really horrible, abusive family,” and recalls perceiving Mormon families as stable: “And to me, what was strange is I saw them as pretty happy. A lot of them got education. A lot of them had good jobs. A lot of them stayed married.” She also recounts that in LDS teaching materials “it was very clear that homosexuality is a sin,” and states her later refusal to donate: “I’m not paying tithing to a organization that rapes and molests people, children, women, and then has a cottage industry of legal teams that cover it up just like the Catholics.”

“I think that it’s fair to say that the church saved me from a really horrible, abusive family.” (source 73a4004f…)

“And to me, what was strange is I saw them as pretty happy. A lot of them got education. A lot of them had good jobs. A lot of them stayed married.” (source 73a4004f…)

“it was very clear that homosexuality is a sin.” (source 73a4004f…)

“I’m not paying tithing to a organization that rapes and molests people, children, women, and then has a cottage industry of legal teams that cover it up just like the Catholics.” (source 73a4004f…)

§Where sources disagree

§Whether the Church holds enforceable rights in the term ‘Mormon’

• The Church and Intellectual Reserve assert nearly two centuries of continuous use of MORMON-incorporating marks, forming a family of marks associated with the Church.

  “Plaintiffs have continuously used in commerce marks incorporating the term MORMON for nearly 200 years.” (source b7842aa7…)

• The defendants contend the term is generic and, to the extent any rights existed, was abandoned; no one controls it.

  “No single source, including the Church, has the legal right to control the use of “Mormon.”” (source 58d50410…)

• The EFF amicus argues ‘Mormon’ is popularly understood as a term for a shared way of life, comparable to ‘Catholic’.

  “the term at issue, “Mormon,” is popularly understood to refer to a way of life that is common to many and owned by none” (source e2f4e0fe…)

§Whether consumers are actually confused about Mormon Stories’ affiliation with the Church

• The complaint alleges actual marketplace confusion, quoting comments on the podcast’s pages.

  “I stumbled upon the Mormon Stories podcast, thinking it was church affiliated. It was quickly evident how anti it was.” (source b7842aa7…)

• The defendants say even the Church’s own examples show no actual or likely confusion, and that most cited comments were not posted on the podcast’s pages.

  “In truth, only 6 comments in paragraph 54 of the Complaint were posted on the MORMON STORIES Facebook or YouTube pages.” (source 58d50410…)

• A commentator on the Mormon Land podcast doubts confusion is plausible after brief listening.

  “I don’t think that anyone who listened to John for five or ten minutes would really be confused that this is an official podcast of the church” (source 22a50eb2…)

• A commentary piece supporting the Church says many people report having been misled by the branding.

  “I know tons of people who were misled into thinking Mormon Stories is an official Church podcast, just to stumble into anti-Mormon material.” (source 510d476c…)

§Whether the lawsuit is aimed at suppressing criticism

• The Church says the case does not target speech content and acknowledges the defendants’ First Amendment right to criticize.

  “This case is not about silencing criticism. The Church’s claims do not target the content of Defendants’ speech at all. Nor is it about ownership or control of the word Mormon.” (source 53abe0b4…)

• The defendants allege the suit’s real motive is to silence or limit the podcast’s reach.

  “the present lawsuit is not motivated by a genuine concern over source affiliation confusion, but instead by a desire to silence, or at a minimum limit the reach of, the

content, opinions, and viewpoints shared on the MORMON STORIES podcast” (source 58d50410…)

• A commentary video frames the suit as being about institutional influence rather than branding.

  “this isn’t really about branding. This is about influence. He has it. They’re losing it.” (source da5daec1…)

§Whether the Church’s 20-year delay bars its claims

• The defendants argue open, widespread use for two decades triggers a presumption of laches and severe prejudice.

  “Defendants’ widespread, open use of MORMON STORIES for decades leaves no room for an inference other than the Church having knowledge of the accused actions—or at a minimum constructive knowledge—long before it filed this case, thus triggering a presumption of laches” (source a8ce7c13…)

• The Church argues laches is fact-intensive, cannot be resolved on the pleadings, does not bar injunctive relief, and does not apply to willful infringement.

  “laches “does not prevent a plaintiff from obtaining injunctive relief,” DayCab Co., Inc. v. Prairie Tech., LLC, 67 F.4th 837, 856 (6th Cir. 2023), which is all Plaintiffs seek on their trademark claims” (source 53abe0b4…)

§Whether the Rogers test should shield the podcast title

• The defendants and EFF argue Rogers applies to expressive-work titles and should resolve the case early.

  “the test first set forth in Rogers v. Grimaldi, and adopted in varying forms by courts around the nation, is a necessary shield against the trademark owner’s sword” (source e2f4e0fe…)

• The Church argues Jack Daniel’s forecloses Rogers where the accused use functions as a source identifier.

  “Because Defendants clearly use the contested marks as trademarks, they cannot rely on Rogers or any other test to “escape from the likelihood-of-confusion inquiry and \[as\] a shortcut to dismissal.”” (source 53abe0b4…)

§Whether the intervention motion raises justiciable questions about the terms’ pre-institutional history

• The movant argues the Church’s own pleadings simultaneously treat the terms as historical/religious record and as exclusive marks, and that this creates a legally protectable interest without adjudicating theology.

  “Plaintiffs simultaneously assert that these terms denote a historical narrative and religious record involving ancient peoples and a historical figure while also claiming they are exclusive marks uniquely associated with Plaintiffs.” (source 458e5a9b…)

• The Church argues the movant’s position depends on religious-historical questions a secular court cannot decide and that he lacks standing.

  “Movant has not identified an actual or imminent, not conjectural or hypothetical injury in fact. Accordingly, Movant lacks standing.” (source 9b94c24e…)

§Whether the Church’s requested disclaimer was a reasonable remedy

• Commentary supporting the Church says the disclaimer request was modest and did not touch content.

  “the “unreasonable demand” that made Dehlin walk away was that the Church, in addition to modifying those branding elements, just asked them to put a brief, simple disclaimer at the beginning of their episodes stating they aren’t affiliated with the Church” (source 510d476c…)

• The defendants say they had already stated non-affiliation from the outset and made numerous voluntary changes.

  “From the beginning, OSF’s website stated that OSF is “a secularly based organization with no affiliation to the LDS church.”” (source 58d50410…)

• The Church responds that the existing disclaimer is buried and absent elsewhere.

  “This disclaimer is on the bottom of www.mormonstories.org, after scrolling down the equivalent of four pages” (source 53abe0b4…)

§What this corpus does not establish

• The corpus contains no court ruling on the motion to dismiss, the motion to intervene, or any of the trademark or copyright claims; every filing is briefing, not adjudication.
• No Church response in the corpus addresses the defendants’ specific allegations of false sworn declarations of continued use or an altered specimen submitted to the USPTO.
• The corpus does not establish the Church’s internal decision-making process — who decided to sue, when, or why enforcement began in November 2025 rather than earlier.
• No document in the corpus provides the Church’s own account of the failed mediation; the mediation is described only by news coverage and by commentators.
• The corpus does not contain the Church’s 2015 press release, its Style Guide, or President Nelson’s 2018 statements in primary form; they are described only through other parties’ filings and commentary.
• Nothing in the corpus establishes the Church’s financial resources, litigation budget, or whether it has sued or threatened other Mormon-themed podcasts beyond the examples asserted by EFF and the defendants.
• The corpus does not establish how many people, if any, were in fact confused about Mormon Stories’ affiliation; both sides characterize the same comment evidence differently.
• The Oaks BYU address and the Christian-identity call-in episode are not connected in the corpus to the litigation by any source other than the defendants’ allegation about a February 10, 2026 talk.

Assembled by an X-Ray archive from 22 captured sources; 75 quotes machine-checked, 0 dropped. Model: claude-opus-5 (entity-page-v2). Generated 2026-08-26. Every line reports what the captured sources say — this page adjudicates nothing.