Westmore · UDRP DecisionAdminvestorservices.com, Adminvestorservices.net, Adminvestorsservices.com
The Panel consolidated claims against three nominally different registrants after finding common control, including closely timed registrations, common naming patterns, similar contact details, and coordinated use. It found the three domain names confusingly similar to the Complainant’s ADM trademark, found no rights or legitimate interests, and concluded that targeting, impersonation-related use, and passive holding established bad-faith registration and use. Transfer of all three domain names was ordered.
The timeline behind adminvestorservices.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind adminvestorservices.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The case illustrates how coordinated registrations across multiple nominal registrants and registrars may be consolidated where the record shows common control. It also shows the combined significance of a recognizable trademark, business-related added terms, impersonation evidence, email configuration, and passive holding in satisfying the UDRP elements.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Archer-Daniels-Midland Company v. Vanesa Ruz Garcia, Alvaro Requena Aranda, Guillermo Urraca, adm Case No. D2025-4527 1. The Parties The Complainant is Archer-Daniels-Midland Company, United States of America (“United States”), represented by Innis Law Group LLC, United States. The Respondents are Vanesa Ruz Garcia, Spain, Alvaro Requena Aranda, Spain, and Guillermo Urraca, adm, Spain. 2. The Domain Names and Registrars The disputed domain name <adminvestorservices.com> is registered with Nicenic International Group Co., Limited. The disputed domain name <adminvestorservices.net> is registered with NameCheap, Inc. The disputed domain name <adminvestorsservices.com> is registered with Name SRS AB (altogether the “Registrars”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 31, 2025. On November 3, 2025, the Center transmitted by email to the Registrars a request for registrar verification in connection with the disputed domain names. On November 4, 2025, the Registrars transmitted by email to the Center their verification responses disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (“unknown”) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 4, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaints for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on November 4, 2025, with a consolidation request. page 2 The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on November 7, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 27, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on November 28, 2025. The Center appointed Kiyoshi Tsuru as the sole panelist in this matter on December 8, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant, Archer-Daniels-Midland Company, also known as “ADM”, is a global agribusiness corporation founded in 1902. The Complainant holds the following trademark registrations, among others: Trademark Registration No. Date of Registration Classes Jurisdiction ADM 1386430 March 18, 1986 Classes 1, 4, 12, 16, 29, 30, 31, and 39 United States ADM 2766613 September 23, 2003 Classes 16, 35, 36 and 42 United States ADM 000913194 February 15, 2001 Classes 1, 4, 5, 29, 30, 31, 33, and 39 European Union ADM 3481336 December 5, 2023 Class 33 Argentina ADM 7689652 February 11, 2025 Class 40 United States The Complainant also owns the domain name <adm.com>, which resolves to the Complainant’s official website. The Complainant’s domain name was registered on October 12, 1994. The disputed domain names <adminvestorservices.com>, <adminvestorsservices.com> and <adminvestorservices.net> were registered between September 23, 2025, and October 29, 2025. At the time of this Decision, said disputed domain names are inactive. However, the Complainant asserts that the disputed domain names previously resolved to websites that, without authorization, used the Complainant’s registered trademark logo, in an intent to impersonate the Complainant to promote investment services. The Complainant has provided evidence that at least two email addresses were created associated with the <adminvestorservices.com> and <adminvestorservices.net> disputed domain names. page 3 5. Parties’ Contentions The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant contends the following: A. Complainant That it has satisfied each of the elements required under the Policy for a transfer of the disputed domain names. That it operates in approximately 200 countries, owns more than 800 facilities worldwide, and employs more than 38,000 people, with worldwide net sales reaching USD 93 billion in 2023. That it places a high priority on safeguarding the security, and trust associated with its online communications in order to preserve the goodwill and reputation attached to its ADM trademark. I. Identical or Confusingly Similar That through more than a century of continuous commercial use and extensive international operations, it has built substantial goodwill. That the ADM trademark has been consistently recognized in prior UDRP decisions as well known and famous. That the disputed domain names incorporate the Complainant’s trademark in its entirety (and cites Osram Sylvania, Inc. v. Jason Blevins, WIPO Case No. D2009-0233; Archer-Daniels-Midland Company v. Elaine Watson, WIPO Case No. 2024-3219; Archer-Daniels-Midland Company v. Maleek Berry, ADM Company, WIPO Case No. D2024-3131; Archer-Daniels-Midland Company v. Repossessed by Go Daddy, WIPO Case No. D2024-2189; Archer-Daniels-Midland Company v. ABBVIE inc, WIPO Case No. D2024-0737; Archer- Daniels-Midland Company v. Rohit Kinra, WIPO Case No. D2024-0413; Archer-Daniels-Midland Company v. Matarr Njjie, WIPO Case No. D2023-5125; Archer-Daniels-Midland Company v. Kali Willy, WIPO Case No. D2023-4177; Archer-Daniels-Midland Company v. Bora Kira, Anderson Doug Mercury Co, WIPO Case No. D2023-3888). That the addition of the terms “investorservices” or “investorsservices” appears to have been deliberately chosen to create an impression of legitimacy, as the Complainant offers investment services through its subsidiary ADM Investor Services, Inc., operating under the domain name <admis.com>. That such terms directly reference the Complainant’s legitimate investor services activities and reinforce the likelihood of confusion, falsely suggesting an affiliation with or endorsement by the Complainant. That the Complainant has brought a number of additional successful UDRP proceedings relating to other fraudulent domains, which panels determined to have been identical or confusingly similar to the Complainant’s mark. II. Rights or Legitimate Interests That the Respondents have used the disputed domain names as part of a deceptive scheme aimed at misleading third parties and tarnishing the Complainant’s trademark for commercial gain. That, as of October 31, 2025, the disputed domain name <adminvestorservices.com> continued to resolve to a fraudulent website reproducing the Complainant’s trademarks, while as of November 3, 2025, the disputed domain name <adminvestorsservices.net> similarly resolved to a fraudulent website containing the Complainant’s trademarks as well as information closely mirroring the Complainant’s legitimate investor services content. page 4 That the disputed domain name <adminvestorsservices.com> was inactive as of October 31, 2025. The Respondents’ use of the disputed domain names to impersonate the Complainant and deceive Internet users precludes any finding of a bona fide offering of goods or services or of legitimate noncommercial or fair use. III. Registered and Used in Bad Faith That the Respondents necessarily had knowledge of the Complainant’s company, trademarks, and business activities when registering the disputed domain names. That, considering the Complainant’s longstanding international reputation of the Complainant’s marks, the registration of the disputed domain names is on itself sufficient for a finding of bad faith. That the Respondents’ impersonation of the Complainant through the disputed domain names is inherently harmful to the Complainant and its existing and prospective business relationships, as it involves the Respondents’ posing as the Complainant and/or its employees and using email addresses associated with the disputed domain names to mislead third parties. That such conduct evidences an intentional attempt to trade off on the goodwill associated with the Complainant’s mark.). B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Preliminary Issue - Multiple Registrants The Complainant has submitted a request for consolidation of multiple registrants in the same proceeding, alleging that the disputed domain names are under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. In determining whether a single consolidated complaint can be brought against multiple registrants, panels typically look at whether (i) the domain names or corresponding websites are subject to common control, and (ii) the consolidation would be fair and equitable to all parties. Procedural efficiency would also underpin panel consideration of such a consolidation scenario. See section 4.11.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). Based on the evidence submitted, which has not been contested by the Respondent, the Panel accepts the Complainant’s contention stating that the disputed domain names are subject to common control. All three disputed domain names were registered within close temporal proximity and were shortly thereafter used in an identical manner to carry out the same fraudulent scheme. Based on the uncontested allegations of the Complainant, the disputed domain names resolved to nearly identical webpages falsely purporting to offer investor services on behalf of the Complainant. Although the registrants are nominally different, they share significant indicia of common control, including a common location in Spain and similarly structured email addresses using the “@prontomail.com” domain. In addition, the disputed domain names themselves follow the same composition pattern, combining the Complainant’s trademark with the terms “investorservices” or “investorsservices,” which further demonstrates coordinated conduct and supports a finding of common control. Considering the above, the Panel accepts that the disputed domain names are subject to common control and thus finds that consolidation would be fair and equitable to all Parties under Paragraph 3(c) of the Rules. page 5 Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. 6.2 Substantive Issues Paragraph 4(a) of the Policy sets out the three requirements that the Complainant must prove in order to successfully request remedies: (i) that the disputed domain names are identical or confusingly similar to a trademark or service mark to which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in connection to the disputed domain names; and (iii) that the disputed domain names have been registered and are being used in bad faith. Given the Respondent’s default and therefore, failure to specifically address the case merits as they relate to the three UDRP elements, the Panel may decide this proceeding based on the Complainant’s undisputed factual allegations under paragraphs 5(f), 14(a), and 15(a) of the Rules (see Joseph Phelps Vineyards LLC v. NOLDC, Inc., Alternative Identity, Inc., and Kentech, WIPO Case No. D2006-0292; Encyclopaedia Britannica, Inc. v. null John Zuccarini, Country Walk, WIPO Case No. D2002-0487; see also WIPO Overview 3.0, section 4.3). A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain names. WIPO Overview 3.0, section 1.7. The Complainant has shown rights in respect of the ADM trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The disputed domain names entirely reproduce the Complainant’s ADM trademark. The Panel finds that the Complainant’s ADM trademark is recognizable within the disputed domain names. It is also well established that the addition of the generic Top-Level Domains (“gTLD”) “.com” and “.net” is viewed as a standard registration requirement and as such is typically disregarded under the first element confusing similarity test. WIPO Overview 3.0, section 1.11.1. Accordingly, the disputed domain names are confusingly similar to the Complainant’s ADM trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with page 6 relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain names. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain names such as those enumerated in the Policy or otherwise. Specifically, the Respondent has failed to submit evidence of bona fide or legitimate noncommercial or fair use of the disputed domain names. No evidence has been filed in connection with the Respondent being commonly known by the disputed domain names. Furthermore, the Panel considers that the composition of the disputed domain names carries a risk of implied affiliation with the Complainant. WIPO Overview 3.0, section 2.5.1. The Panel also notes that at least two email addresses were created in connection with the disputed domain names, which represents a risk that such could be used for illegitimate activities. Therefore, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. The Complainant has ascertained its rights over the ADM well-known trademark. The dates of registration of said trademark and further registered domain names of the Complainant significantly precede the date of registration of the disputed domain names. The Complainant has submitted uncontested information showing that it is a global agribusiness corporation with more than a century of continuous commercial use and extensive international operations in approximately 200 countries, with hundreds of facilities worldwide, and more than 38,000 employees. These facts collectively support the conclusion that the ADM trademark enjoys substantial goodwill and a high degree of public recognition as a well-known trademark (see Audi AG and Volkswagen AG v. Glenn Karlsson-Springare WIPO Case No. D2011-2121; Tetra Laval Holdings & Finance S.A. v. Ricardo Lopez Ortega WIPO Case No. D2022-4037; and Swarovski AG v. Marius Muller WIPO Case No. D2016-2315). The Panel finds that the composition of the disputed domain names, reproducing the Complainant’s famous mark, added by terms directly related to one of the activities of the Complainant, indicates that the Respondent registered the disputed domain names with the Complainant in mind to target the Complainant. Moreover, the Complainant asserts, and the Respondent has not contested, that the Respondent previously caused the disputed domain names <adminvestorservices.com> and <adminvestorsservices.net> to resolve to websites that, without authorization, have used the Complainant’s ADM trademark on webpages displaying the Complainant’s logo and impersonating the Complainant to promote investment services. The evidence shows that the Respondent has imitated the look and feel of the Complainant’s website. In addition, and as noted above, the Complainant has provided evidence that at least two email addresses were created in connection with the disputed domain names, which represents a risk that such could be used for illegitimate activities. Panels have held that the use of a domain name for illegitimate activity here, claimed as impersonation/passing off, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names <adminvestorservices.com> and <adminvestorsservices.net> constitute bad faith under the Policy. page 7 Panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and well-known character of the Complainant’s trademark, and the composition of the disputed domain name <adminvesstorservices.com> and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <adminvestorservices.com>, <adminvestorservices.net> and <adminvestorsservices.com> be transferred to the Complainant. /Kiyoshi Tsuru/ Kiyoshi Tsuru Sole Panelist Date: December 22, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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