Dave Levin defeated Brown in a one-fall match on April 27, 1944 in Kansas City, Kansas, and laid claim to the title. However, Brown claimed that the title could only change hands in a two-out-of-three falls match.
↑Wrestling-Titles: Orville Brown - biography: "On Nov. 10, 1939 at Bridgeport, Conn., Bobby Bruns defeated Jack Pfefer's world light heavyweight champion Maurice Boyer. From that point forward in New England and the Atlantic Coast, the title changed to a heavyweight title and Pfefer billed Bruns as heavyweight world champion .. On Jan. 18, 1940, Bruns defended this title in a clean win over Brown."
↑LegacyOfWrestling Bobby Bruns Wrestling History: "On January 11, 1940, Bruns beat Andy Mexiner in two-straight falls in Kansas City. A week later, he returned to the Memorial Hall to wrestle Orville Brown for the vacant World Heavyweight Title, recognized by the state of Kansas and by promoter George Simpson. He won the first in 40:30 and then the 3rd in 5:00 to capture the championship."