Westmore · UDRP DecisionAresmgtcorps.com
The Panel ordered transfer of <aresmgtcorps.com>. It found the domain confusingly similar to Complainant’s ARES mark because the mark remained recognizable despite the added abbreviations “mgt” and “corps.” Complainant established a prima facie case that Respondent lacked rights or legitimate interests, which Respondent did not rebut. Bad faith was established under the passive-holding doctrine based principally on the distinctiveness and reputation of the ARES mark, the composition and non-use of the domain, and Respondent’s failure to provide evidence of any actual or contemplated good-faith use.
The timeline behind aresmgtcorps.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 aresmgtcorps.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates a straightforward application of the passive-holding doctrine where a domain reproduces a distinctive mark, adds abbreviations associated with the complainant’s field or identity, contains no substantive website, and is left unexplained by a defaulting respondent. It also shows that an allegation of configured email capability need not be decisive where the totality of passive-holding circumstances independently establishes bad faith.
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 Ares Management LLC v. Louise Hancovsky Case No. D2026-0131 1. The Parties Complainant is Ares Management LLC, United States of America (“U.S.”), represented by Greenberg Traurig, LLP, U.S. Respondent is Louise Hancovsky, U.S. 2. The Domain Name and Registrar The disputed domain name <aresmgtcorps.com> (the “Disputed Domain Name”) is registered with Cosmotown, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 13, 2026. On January 14, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On January 17, 2026, 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 (Not provided) and contact information in the Complaint. The Center sent an email communication to Complainant on January 19, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on January 23, 2026. 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 Respondent of the Complaint, and the proceedings commenced on January 26, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 15, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on February 18, 2026. page 2 The Center appointed Douglas M. Isenberg as the sole panelist in this matter on February 23, 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 Complainant states that it is “a subsidiary of Ares Management, L.P. (collectively, ‘Ares’), which is a publicly traded, leading global alternative asset manager with $596 billion of assets under management (‘AUM’) and over 4,200 employees”; that “Ares is headquartered in Los Angeles, with over 55 global offices, including the United States, Europe, Asia, the Middle East, and Australia”; and that “[s]ince March 19, 2002, Ares has owned the domain name <AresMgmt.com> and since at least 2007, Ares has promoted and offered services through its website hosted on that domain name.” Complainant states, and provides documentation in support thereof, that “Ares has adopted and used the mark and trade name ARES continuously since at least September 1997”; and that “Ares is the owner of a well-established family of famous trademarks and has trademark registrations that cover 57 countries,” including the following: - U.S. Reg. No. 3,014,171 for ARES (registered November 8, 2005) - U.S. Reg. No. 3,925,366 for ARES MANAGEMENT (registered March 1, 2011) - U.S. Reg. No. 3,925,365 for ARES CAPITAL MANAGEMENT (registered March 1, 2011) These registrations are referred to herein as the “ARES Trademark”. The Disputed Domain Name was created on November 25, 2025. Complainant states that “[t]here is no content posted on the Disputed Domain Name and Complainant is not aware of any content ever having been posted on the Disputed Domain Name.” Although Complainant did not provide a screenshot confirming this, the Panel visited the website connected to the Disputed Domain Name on March 6, 2026, and found only an “Index” page with links to three URLs associated with the Disputed Domain Name, none of which had any substantive content. 1 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name. Notably, Complainant contends that: - The Disputed Domain Name is identical to the ARES Trademark because, inter alia, “[t]he Disputed Domain Name incorporates Complainant’s ARES mark in full, changing the mark only by adding the letters ‘mgt’ and ‘corps’ at the end”; “Respondent used ‘mgt’ as an abbreviation for the term ‘management’”, which is part of Complainant’s corporate name, Ares Management, LLC, and this is the general understanding of this acronym... and only common use of this combination of letters in the English language that Complainant is aware of”; “[s]imilarly, it seems clear that Respondent used ‘corps’ as an abbreviation for the term ‘corporations’, and this is the general understanding of this acronym”; and “[t]he addition of the letters ‘mgt’ and ‘corps’ to Complainant’s famous ARES 1 “Noting in particular the general powers of a panel articulated inter alia in paragraphs 10 and 12 of the UDRP Rules, it has been accepted that a panel may undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision, in particular to affirm or corroborate a party’s contention. This may include visiting the website linked to the disputed domain name in order to obtain more information about the respondent or its use of the domain name....” WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.8. page 3 mark does not distinguish the Disputed Domain Name but instead actually increases the likelihood of confusion based on the direct association of those words with Complainant’s financial services and the similarity to Complainant’s website and email addresses.” - Respondent has no rights or legitimate interests in the Disputed Domain Name because, inter alia, “[t]here is no content posted on the Disputed Domain Name and Complainant is not aware of any content ever having been posted on the Disputed Domain Name”; “[t]he pertinent WHOIS information identified the registrant of the Disputed Domain Name as ‘Louise Hancovsky’ constraining the Panel to conclude that Respondent is not commonly known by the Disputed Domain Name”; “Respondent has never operated any bona fide or legitimate business under the Disputed Domain Name, and Respondent’s use of the Disputed Domain Name does not constitute a legitimate non-commercial or fair use of the domain name”; “Complainant has not authorized, licensed, or consented to Respondent’s registration and use of a domain name incorporating Complainant’s ARES trademarks or any confusingly similar variations thereof”; and “to Complainant’s knowledge, there are no prior trademark applications or registrations in the name of Respondent for any mark incorporating the term ‘ARES’ anywhere in the world.” - The Disputed Domain Name was registered and is being used in bad faith because, inter alia, “Complainant’s Marks have a strong reputation and are substantially used worldwide,” invoking application of the passive-holding doctrine; “Respondent has set up the Disputed Domain Name for use to create email addresses and send email messages by creating MX (mail exchange) records,” which “indicate use for email, which evidences a likelihood of additional bad-faith use of the Disputed Domain Name to engage in fraudulent email or phishing communications”; and Respondent did not reply to correspondence sent by Complainant to Respondent after Complainant obtained Respondent’s identity during the course of this proceeding. B. Respondent Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar Based upon the trademark registrations cited by Complainant, it is apparent that Complainant has rights in and to the ARES Trademark. As to whether the Disputed Domain Name is identical or confusingly similar to the ARES Trademark, the relevant comparison to be made is with the second-level portion of the Disputed Domain Name only (i.e., “aresmgtcorps”) because “[t]he applicable Top-Level Domain (‘TLD’) in a domain name (e.g., ‘.com’, ‘.club’, ‘.nyc’) is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test”. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.11.1. As set forth in section 1.7 of WIPO Overview 3.1: “in cases where a domain name incorporates the entirety of a trademark..., the domain name will normally be considered confusingly similar to that mark.” Further, as set forth in section 1.8 of WIPO Overview 3.1: “Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element.” Accordingly, inclusion of “mgt” (an abbreviation for “management”, which appears in some registrations for the ARES Trademark) and “corps” (an abbreviation for “corporations”) do nothing to avoid confusing similarity. The Panel finds the first element of the Policy has been established. page 4 B. Rights or Legitimate Interests Complainant has argued that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because, inter alia, “[t]here is no content posted on the Disputed Domain Name and Complainant is not aware of any content ever having been posted on the Disputed Domain Name”; “[t]he pertinent WHOIS information identified the registrant of the Disputed Domain Name as ‘Louise Hancovsky’ constraining the Panel to conclude that Respondent is not commonly known by the Disputed Domain Name”; “Respondent has never operated any bona fide or legitimate business under the Disputed Domain Name, and Respondent’s use of the Disputed Domain Name does not constitute a legitimate non-commercial or fair use of the domain name”; “Complainant has not authorized, licensed, or consented to Respondent’s registration and use of a domain name incorporating Complainant’s ARES trademarks or any confusingly similar variations thereof”; and “to Complainant’s knowledge, there are no prior trademark applications or registrations in the name of Respondent for any mark incorporating the term ‘ARES’ anywhere in the world.” WIPO Overview 3.1, section 2.1, states: “Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving that a respondent lacks rights or legitimate interests in a domain name may result in the often impossible 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 relevant evidence demonstrating rights or legitimate interests in the domain name. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element.” The Panel finds that Complainant has established its prima facie case and without any evidence from Respondent to the contrary, the Panel is satisfied that Complainant has satisfied the second element of the Policy. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Whether a domain name is registered and used in bad faith for purposes of the Policy may be determined by evaluating four (non-exhaustive) factors set forth in the Policy: (i) circumstances indicating that the registrant has registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the registrant’s documented out-of-pocket costs directly related to the domain name; or (ii) the registrant has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the registrant has engaged in a pattern of such conduct; or (iii) the registrant has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, the registrant has intentionally attempted to attract, for commercial gain, Internet users to the registrant’s website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the registrant’s website or location or of a product or service on the registrant’s website or location. Policy, paragraph 4(b). WIPO Overview 3.1, section 3.3 (citing Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003), states: From the inception of the UDRP, panelists have found that the non-use of a domain name (including a blank or “coming soon” page) would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panelists have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. page 5 Factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s taking active steps to conceal its identity or (iv) the use of false or inaccurate contact details (noted to be in breach of the respondent’s registration agreement). Taking the above factors into consideration, panels assess the overall plausibility of any (claimed) good faith use to which the domain name may be put in light of the composition of the domain name in relation to the relevant mark, such that, the more arbitrary or distinctive a mark the less plausible a claimed non-infringing good faith use is likely to be, and vice versa. Here, the ARES Trademark appears to be distinctive and appears to have a high degree of reputation given that it is protected by numerous registrations in 57 countries, the oldest of which Complainant claims was used more than 28 years ago, and that Complainant operates in 55 offices and employs more than 4,200 people. Further, Respondent did not submit a response or provide any evidence of actual or contemplated good-faith use. The Panel finds that 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 Name <aresmgtcorps.com> be transferred to Complainant. /Douglas M. Isenberg/ Douglas M. Isenberg Sole Panelist Date: March 6, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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