American Bell International, Inc. v. Islamic Republic of Iran
United States District Court for the Southern District of New York
474 F. Supp. 420 (1979)
Bell (plaintiff) sought to enjoin a bank from honoring a letter of credit after Iran's post-revolutionary government (defendant) repudiated its contract with Bell but still demanded repayment under a linked letter-of-credit structure; Bell argued the payment demand, made in the name of the new "Government of Iran" rather than the original "Imperial Government," was nonconforming and that the whole transaction was fraudulent.
Whether a court may issue a preliminary injunction barring an issuer of a letter of credit from making payment to the beneficiary only if the plaintiff shows the demand does not conform to the letter's requirements or that the transaction was fraudulent.