Westmore · UDRP decision
WIPO · Case No. D2025-4914

Ashcongress.org + 5 more domains

TransferWIPO-indexed · informational, not legal advice

The Panel consolidated the proceeding against six nominally different registrants after finding indications of common control and determining that consolidation was fair and equitable. All six domain names incorporated the Complainant’s ASH mark with meeting-related terms, years, numbers, or hyphens. The Respondents filed no response. The Panel found confusing similarity, no rights or legitimate interests, and bad-faith registration and use. It found that <ash-2025.org> had been used to impersonate the Complainant and applied the passive-holding doctrine to the other five domain names. Transfer of all six domain names was ordered.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-21
Panelist(s)
Souter, George R. F.
Complainant
American Society of Hematology, Inc.
Respondent
AJMAL KHAN, JOPTECH Amit Kumar ASH Meetings Ashish Kumar, Ash25 Taylor John Vikas singh
Disputed domain(s)
ashcongress.org, ashcongress25.org, ashmeetings.org, ash-2025.org + 2 more
Citation weightCited by 1 later decision
Domain history UDRP Intelligence

The timeline behind ashcongress.org

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 ashcongress.org — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Outcome by domain

How each disputed name was decided in this proceeding.

ashcongress.orgTransferred
ashcongress25.orgTransferred
ashmeetings.orgTransferred
ash-2025.orgTransferred
ash25.netTransferred
2025ash.orgTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of ashcongress.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a coordinated cluster of domains aimed at a trademark owner’s annual event may be consolidated despite nominally different registrants. It also shows that active impersonation through one domain can be evaluated alongside passive holding of related domains, with common naming patterns, respondent default, registration-data concerns, and the absence of any plausible good-faith use supporting transfer across the cluster.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-21
Panel
Souter, George R. F.
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION American Society of Hematology, Inc. v. ASH Meetings; Vikas singh; AJMAL KHAN, JOPTECH; Ashish Kumar, Ash25; Amit Kumar; and Taylor John Case No. D2025-4914 1. The Parties The Complainant is American Society of Hematology, Inc., United States of America (“United States”), represented by Nelson Mullins Riley & Scarborough LLP, United States. The Respondents are ASH Meetings, India; Vikas singh, India; AJMAL KHAN, JOPTECH, India; Ashish Kumar, Ash25, India; Amit Kumar, India; and Taylor John, India. 2. The Domain Names and Registrars The disputed domain names <ashcongress.org> and <2025ash.org> are registered with NameCheap, Inc. The disputed domain names <ashcongress25.org>, <ashmeetings.org>, and <ash-2025.org> are registered with GoDaddy.com, LLC. The disputed domain name <ash25.net> is registered with Tucows Domains Inc. (together the “Registrars”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 25, 2025. On November 26, 2025, the Center transmitted by email to the Registrars requests for registrar verification in connection with the disputed domain names. On November 26 and December 1, 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 Respondents (Domains By Proxy, LLC; Vikas Singh; Ajmal Khan, Joptech / Privacy service provided by Withheld for Privacy ehf; Contact Privacy Inc. Customer 0172709097; Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 2, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) 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 disputed domain names are under common control. The Complainant filed an amended Complaint on December 4, 2025. 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 December 9, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 29, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on December 30, 2025. The Center appointed George R. F. Souter as the sole panelist in this matter on January 7, 2026. 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 is one of the world’s largest professional societies serving both clinicians scientists around the world in the field of hematology. It was formed as an association more than 60 years ago, and has grown to consist of more than 17,000 members from nearly 100 countries. The Complainant’s mission is to further the understanding, diagnosis, treatment and prevention of disorders affecting the blood, bone marrow and the immunological, hemostatic and vascular systems, by promoting research, clinical care, and education, training and advocacy in hematology. The Complainant has, for more than six decades, sponsored an annual meeting, which is its premier annual education and scientific event in the field of hematology. The Complainant has registered its ASH trademark widely throughout the world in relation to its activities, including United States Registration No. 3,253, 642, registered on June 19, 2007, and United States Registration No. 5,570,785, registered on September 25, 2018. Both of these United States Registrations carry the note that “the mark consists of standard characters without claim to any particular font style, size, or color”. The Complainant’s registrations of its ASH trademark include Indian Registration No. 3708457. The disputed domain name <2025ash.org> was registered on June 8, 2025. The disputed domain name <ashcongress25.org> was registered on October 29, 2025. The disputed domain name <ash25.net> was registered on October 7, 2025. The disputed domain name <ash-2025.org> was registered on August 14, 2025. The disputed domain name <ashcongress.org> was registered on October 14, 2025. The disputed domain name <ashmeetings.org> was registered on November 3, 2025. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain names. page 3 Notably, the Complainant contends that the disputed domain names are under common control, and that the Complainant has never authorised any of the Respondents to use its ASH trademark in connection with the registration of a domain name, or otherwise. The Complainant has also provided the Panel with an instance of use of the disputed domain name <ash-2025.org> to impersonate the Complainant in the course of its business. B. Respondents None of the Respondents replied to the Complainant’s contentions. 6. Discussion and Findings Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the disputed domain name domain registrants are the same entity or mere alter egos of each other, or 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. The disputed domain name registrants did not comment on the Complainant’s request. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel has considered whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.11.2. As regards common control, the Panel notes that the disputed domain names appear to be designed for a concerted attempt to interfere with the Complainant’s business in general, and the Complainant’s 2025 Annual meeting in particular. Further, the Panel notes that the registration details of all the disputed domain names list the country as India and appear to contain false or incomplete physical address information. Moreover, the disputed domain name registrants have not objected to the Complainant’s consolidation request, or otherwise participated in this proceeding. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. 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. A. Identical or Confusingly Similar The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel finds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The elements added to the Complainant’s mark (such as, where applicable, hyphens and the terms or numbers “congress”, “meetings”, “25”, or “2025”) in each disputed domain name do not prevent a finding of confusing similarity. The Panel finds the first element of the Policy has been established. page 4 B. Rights or Legitimate Interests 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. Panels have held that the use of a domain name for illegitimate activity, here claimed impersonation/passing off and other types of fraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith In the Panel’s opinion, it is implausible that the disputed domain names were designed without having the Complainant’s trademark in mind, which justifies a finding of registration in bad faith, and the Panel so finds. It is well-established in prior decisions under the Policy that the use of a disputed domain name, found to be confusingly similar to a complainant’s trademark, to impersonate the complainant constitutes use of that domain name in bad faith. That is certainly the case in connection with the use of the disputed domain name <ash-2025.org>. In connection with the other five disputed domain names, the established doctrine of passive holding can be applied, and the Panel finds in the circumstances of this case that passive holding of these five disputed domain names would not prevent a finding of bad faith. Here, the relevant factors pointing to bad faith include: (i) the reputation of the Complainant and its trademarks, (ii) the composition of the disputed domain names, (iii) the failure of the Respondent to submit a Response or to provide any evidence of actual or contemplated good-faith use, (iv) the Respondent’s concealing its identity and use of false or incomplete registration data, and (v) the implausibility of any good faith use to which the disputed domain names may be put. 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 <ashcongress.org>, <ashcongress25.org>, <ashmeetings.org>, <ash-2025.org>, <ash25.net>, and <2025ash.org> be transferred to the Complainant. /George R. F. Souter/ George R. F. Souter Sole Panelist Date: January 21, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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