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When Marshall Cooper formed a rival League in 1932 in protest of Judge Hugh Walker's rule changes, he awarded a franchise to Buffalo, New York. The Buffalo franchise, whose nickname is never learned, joins The League in 1937, when Walker is forced to sell his interest. Buffalo survives until 1942, when The League is forced to contract during World War II. It is unknown if the team is folded outright, or survived as a relocated franchise.