Westmore · UDRP decision
WIPO · Case No. D2025-5043

Aresmanagementcorporationi.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <aresmanagementcorporationi.com>. It found the domain confusingly similar to the Complainant’s ARES marks, found no rights or legitimate interests based on the unrebutted prima facie case, and found bad-faith registration and use from the later registration, the domain’s composition, passive holding, and active MX records.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-20
Panelist(s)
Fiammenghi, Eva
Complainant
Ares Management LLC
Respondent
zhang honglin
Disputed domain(s)
aresmanagementcorporationi.com
Domain history UDRP Intelligence

The timeline behind aresmanagementcorporationi.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 aresmanagementcorporationi.com — 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
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of aresmanagementcorporationi.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how passive holding can support a transfer where a domain closely targets an established mark and is configured for email. The Panel did not rely on proven phishing; it assessed the MX records together with the domain’s composition, the timing of registration, the mark’s reputation, and the absence of a respondent explanation.

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
2026-01-20
Panel
Fiammenghi, Eva
Full decision
9 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Ares Management LLC v. zhang honglin Case No. D2025-5043 1. The Parties The Complainant is Ares Management LLC, United States of America (“US” o r “United States”), represented by Greenberg Traurig, LLP, United States. The Respondent is zhang honglin, Thailand. 2. The Domain Name and Registrar The disputed domain name <aresmanagementcorporationi.com> is registered with Gname.com Pte. Ltd. (the “Reg istrar”). 3. Procedural History The Complaint was f iled with the WIPO Arbitration and Mediation Center (the “Center”) on December 4, 2025. On December 4, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On December 5, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Redacted for Privacy) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on December 5, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on December 9, 2025. The Center verif ied that the Complaint together with the amended Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on December 10, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was December 30, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on January 2, 2025. page 2 The Center appointed Eva Fiammenghi as the sole panelist in this matter on January 7, 2026. The Panel f inds 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, Ares Management LLC, is a US company operating in the f inancial services sector, specifically in alternative asset management. Founded in 1997, it is a subsidiary of Ares Management Corporation, a publicly traded company listed on the New York Stock Exchange under the ticker symbol “ARES.” The group manages approximately USD 596 billion in assets and provides investment services in credit, private equity, and real estate, with over 4,200 employees and more than 55 of f ices worldwide. The Complainant owns multiple registrations for the ARES trademark in numerous jurisdictions worldwide, including but not limited to the f ollowing: - United States Trademark ARES, Reg. No. 3014171, registered on November 8, 2005, in class 36. - United States Trademark ARES MANAGEMENT, Reg. No. 3925366, registered on March 1, 2011, in class 36. - United States Trademark ARES CAPITAL MANAGEMENT, Reg. No. 3925365, registered on March 1, 2011, in class 36. (together Complainant’s trademarks ARES) The Complainant operates its principal website at “www.aresmgmt.com”, used worldwide to promote its investment management services. The Complainant also owns other related domain names, including <aresmanagement.com>, <aresmanagementrealestate.com>, and <arescapitalmgmt.com>. The disputed domain name <aresmanagementcorporationi.com> was registered on October 20, 2025 with the registrar Gname.com Pte. Ltd. The disputed domain name currently does not resolve to any active website content (passive holding). However, MX records have been conf igured f or email services, suggesting potential f raudulent use such as phishing. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain name. Notably, the Complainant contends that the disputed domain name <aresmanagementcorporationi.com> is conf usingly similar to its well-known trademark ARES. According to the Complainant, the disputed domain name reproduces its trademark in its entirety, merely adding the descriptive terms “management” and “corporationi,” which are closely associated with the Complainant’s corporate name and business. These additions do not prevent a f inding of conf using similarity under the Policy. The Complainant further asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is not affiliated with the Complainant, has never been authorized to use its trademark, and is not commonly known by the disputed domain name. There is no evidence of any bona fide offering of goods or services or legitimate non-commercial use. The Complainant submits that the disputed domain name was registered and is being used in bad faith. The registration occurred in October 2025, long af ter the Complainant’s trademarks became internationally recognized. While the disputed domain name does not resolve to an active website, DNS records show active MX entries, indicating that the disputed domain name is conf igured f or email services. The Complainant argues that this strongly suggests an intent to use the disputed domain name f or f raudulent page 3 purposes, such as phishing or impersonation, by exploiting the similarity to the Complainant’s trademark. In the Complainant’s view, these circumstances demonstrate bad faith under paragraph 4(b)(iv) of the Policy. On this basis, the Complainant requests that the Panel order the transfer of the disputed domain name to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, to succeed a complainant must prove that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; (ii) the respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name was registered and is being used in bad f aith. These elements are discussed in turn below. In considering these elements, paragraph 15(a) of the Rules provides that the Panel shall decide the Complaint on the basis of statements and documents submitted and in accordance with the Policy, the Rules and any other rules or principles of law that the Panel deems applicable. A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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 name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. 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 f inds the mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the trademark f or the purposes of the Policy. WIPO Overview 3.0, section 1.7. The disputed domain name incorporates the Complainant’s trademarks ARES in its entirety, with the addition of the descriptive terms “management” and “corporationi.” These additions do not prevent a f inding of conf using similarity. WIPO Overview 3.0, section 1.8. The applicable generic Top-Level Domain (“.com”) is typically disregarded under the f irst element assessment. WIPO Overview 3.0, section 1.11. The Panel f inds the f irst 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 of ten 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 4 relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Complainant has not authorized the Respondent to use its trademark. There is no evidence that the Respondent is commonly known by the disputed domain name, nor is there evidence of any bona f ide of fering of goods or services, or legitimate noncommercial use. On the contrary, the disputed domain name does not resolve to an active website, and DNS records show active MX entries, suggesting potential use for f raudulent email activities The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, f or 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 f aith. In the present case, the Panel notes that the Respondent registered the disputed domain name in October 2025, many years after the Complainant’s trademarks ARES were registered. The disputed domain name incorporates the Complainant’s trademark in its entirety, with the addition of descriptive terms “management” and “corporationi,” which strongly suggests that the Respondent was aware of the Complainant and its rights at the time of registration. The disputed domain name does not resolve to an active website, as confirmed by the evidence provided, but DNS records show active MX entries, indicating that the disputed domain name is conf igured f or email services and might be used f or illegitimate activity. Having reviewed the record, the Panel f inds the Respondent’s registration and use of the disputed domain name constitutes bad f aith under the Policy. Panels have also found that the non-use of a domain name does not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. In this case, the distinctiveness and reputation of the Complainant’s trademark, combined with the composition of the disputed domain name and the presence of MX records, reinf orce the f inding of bad f aith. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <aresmanagementcorporationi.com> be transf erred to the Complainant. /Eva Fiammenghi/ Eva Fiammenghi Sole Panelist Date: January 20, 2026

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

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