Why Bismarck's final battle was not named for Ushant

What geographic name could be given to the battle in which Bismarck was sunk?

Ushant is the nearest plausible landmark, but so many earlier actions already carry that name that another Battle of Ushant would create confusion.

The naming problem begins with the nearest plausible land reference, Ushant. Naval history already contains numerous Battles of Ushant across the eighteenth century and both world wars, including the Glorious First of June. Adding Bismarck's final action to that sequence would make an already ambiguous label harder to use. Because Bismarck attracts so much attention, the newer usage could also overwhelm writing and searches for the earlier battles.