There is no general rule in naming openings or opening lines in general or gambits. Sometimes it’s the inventor, sometimes the place they lived, they were born, they played the line the first time, and so on. To make it more complicated, openings can have different names in different languages. In germanGerman, the Petroff defence is named russianRussian defence, and Benko Gambit is called Wolga-Gambit. The Sokolski is also called Orang-Utan. So there really is no general rule but in some cases some amusing histories.