Westmore · UDRP decision
WIPO · Case No. D2026-0244

Adm-trading.pro

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <adm-trading.pro>. It found the domain confusingly similar to the Complainant’s ADM trademark because it incorporated ADM in its entirety with the hyphenated term “trading.” The Respondent lacked rights or legitimate interests because there was no authorization, evidence that the Respondent was commonly known by the domain, or bona fide use. Evidence showed that the domain had previously resolved to a website displaying the Complainant’s ADM mark and logo and offering account creation or login functionality without disclosing the absence of any relationship with the Complainant. Despite the Respondent’s assertion that the domain had remained inactive, the Panel found intentional impersonation or, at minimum, an attempt to attract Internet users for commercial gain through confusion, establishing bad-faith registration and use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-11
Panelist(s)
Wegrostek, Manuel
Complainant
Archer-Daniels-Midland Company
Respondent
Nasreen Akhter, MM Tradings
Counsel
Innis Law Group LLC
Disputed domain(s)
adm-trading.pro
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind adm-trading.pro

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 adm-trading.pro — 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 adm-trading.pro.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates that current inactivity does not neutralize documented prior impersonation use. A domain combining a recognizable mark with a term related to the trademark owner’s business, coupled with a website using the owner’s branding and account-access functionality, can support findings on both legitimate interests and bad faith even where definitive proof of completed fraud is absent.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-11
Panel
Wegrostek, Manuel
Full decision
17 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Archer-Daniels-Midland Company v. Nasreen Akhter, MM Tradings Case No. D2026-0244 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 Respondent is Nasreen Akhter, MM Tradings, Pakistan, self-represented. 2. The Domain Name and Registrar The disputed domain name <adm-trading.pro> is registered with OwnRegistrar, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 21, 2026. On January 22, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 23, 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 (unknown / WhoisSecure) and contact information in the Complaint. The Center sent an email communication to the Complainant on January 27, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amendment to the Complaint on January 27, 2026. The Respondent sent email communications to the Center on January 27 and 30, 2026, and February 2, 2026. The Center verified that the Complaint together with the amendment to the 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 Respondent of the Complaint, and the proceedings commenced on February 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 22, 2026. The Response was filed with the Center on February 2, 2026. page 2 The Center appointed Manuel Wegrostek as the sole panelist in this matter on February 25, 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 was founded in 1902 and was originally a food and ingredients company. The business areas of the Complainant now also include printing and publishing, financial and business management services, fuel production, including bioethanol, and biodiesel, logistics services as well as research and development services. The Complainant operates under the initials “ADM” and serves 200 countries, owns more than 800 facilities worldwide, employs over 38,000 people. In 2023, the Complainant’s worldwide net sales were USD 93 billion. The Complainant is the owner of several trademarks for ADM (the “ADM Trademark”), including: - United States Trademark Registration ADM No. 1386430, registered on March 18, 1986, - European Union Trademark Registration ADM No. 000913194, registered on February 15, 2001; and - China Trademark Registration ADM No. 3013670, registered on January 28, 2003. The Complainant is also the owner of domain names including the ADM Trademark, such as the domain name <adm.com>, registered on October 12, 1994. The disputed domain name was registered on January 14, 2026. At the time of the Decision, the disputed domain name resolved to an inactive website. The Complainant provided evidence that the disputed domain name previously resolved to an active website prominently displaying the ADM Trademark and the ADM logo of the Complainant, where users had the option of entering data to create an account or login. The Respondent submitted a response to the Complaint via email, denying any use or registration of the domain in bad faith and refusing to pay a settlement fee to the Complainant, but agreeing to transfer the disputed domain name following a UDRP decision. 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 name. On the first element of the Policy, the Complainant claims that the disputed domain name is confusingly similar to the ADM Trademark. The disputed domain name completely incorporates the ADM Trademark, and the word “ADM” is the most prominent and recognizable portion of the disputed domain name. The disputed domain name was chosen to be confusingly similar to the ADM Trademark, given the Respondent’s use of it on a website along with the ADM Trademark. With regards to similarity, the disputed domain name and the ADM Trademark are also similar in meaning or connotation. Both consist of the same three letters, “ADM”, in the same order with no punctuation. ADM will be perceived by most consumers as an acronym and trademark for the Complainant, given the fame of the mark. Since the only difference is the inclusion of “-TRADING” which, is a direct reference the legitimate investing services of the Complainant, the disputed domain name and the ADM Trademark should be treated as conceptually identical. Further, the disputed domain name and the ADM Trademark are phonetically similar. Regarding the other likelihood of confusion factors, the Respondent is clearly targeting individuals who would like to engage with the Complainant’s page 3 investment services. The Respondent appears to be trying to gain personal data of unsuspecting individuals by having them create an account on or login to the fraudulent website. Any individual who encounters the website associated with the disputed domain name could be misled into believing that the site is somehow affiliated with the Complainant. Finally, the generic top-level domain, “.PRO”, featured in the disputed domain name is viewed as a standard registration requirement and not an element that generally would be taken into consideration when evaluating the identity and similarity of the ADM Trademark and the disputed domain name and should, therefore, not be taken into consideration here. On the second element of the Policy, the Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent has not been commonly known by the disputed domain name, and this is evident by the fact that it was registered on January 14, 2026, and was immediately used in furtherance of a fraudulent scheme. Any legitimate rights or interests in the domain name are negated by the Respondent’s use of the disputed domain name to create a fraudulent website. There is no legitimate reason to register a domain and immediately use it to impersonate a legitimate company. Upon information and belief, the Respondent is not making a legitimate, noncommercial or fair use of the disputed domain name without intent for commercial gain. Instead, as described above, the Respondent is using the disputed domain name to deceive individuals and to tarnish the ADM Trademark. Further, the website under the disputed domain name was, as of January 16, 2026, still active showing the Complainant’s name and logo. Thus, upon information and belief, the Respondent has not made preparations to use the disputed domain name with a bona fide offering of goods or services. Panels have previously determined that such schemes were prima facie showings of an absence of the respondents’ legitimate rights in the disputed domain names. On the third element of the Policy, the Complainant asserts that the Respondent has registered and used the disputed domain name in bad faith. Upon information and belief, the Respondent is using the ADM Trademark, the Complainant’s name, and the Complainant’s robust global online presence in bad faith via the disputed domain name in an attempt to deceive individuals via a fraudulent investment website. The Respondent is aiming to intentionally trade on the goodwill of the Complainant’s fame, trademarks, reputation, and online presence through its disputed domain name, and is in violation of the Complainant’s prior rights and international civil and criminal laws. Immediately after registering the domain on January 14, 2026, the Respondent created a website purporting to be an ADM trading platform and using two images of ADM’s registered trademark logo on a sign. The website appears to be a fraudulent investment app which includes options for “deposit” and “withdraw”. Simply put, the facts of this case can lead to no other conclusion than the Respondent is not only using the disputed domain name in bad faith but registered it in bad faith as well. Security and trust are vital in communications between the Complainant and individuals interested in the company for employment or business, and a fraudulent party impersonating the Complainant is detrimental to both the Complainant and its present and future relationships. Furthermore, panels have consistently determined that domains registered and used to defraud the public are sufficient to make a finding of bad faith. Moreover, the Respondent’s registration of the disputed domain name is “in and of itself sufficient in this case for a finding of bad faith” given that the ADM Trademark is well known internationally. The Respondent’s actions clearly indicate the Respondent’s intentional and bad faith attempts to create a likelihood of confusion with the famous ADM Trademark and trade off the goodwill associated with its ADM Trademark and the Complainant’s domain <adm.com>. B. Respondent The Respondent replied to the Complainant’s contentions via emails, last on February 2, 2026, as follows: The disputed domain name has never been used for any commercial, misleading, or bad-faith purpose. It was merely registered and has remained inactive, with no website content, services, advertisements, or monetization of any kind associated with it. Since the domain name has not been used and has generated no benefit, profit, or value for us, there is nothing to settle financially. The absence of use or content means no harm, loss, or infringement has occurred that would justify a settlement fee. If the Complainant wishes to proceed further, they may pursue cancellation or transfer of the domain through the appropriate registrar or the UDRP process. We have no objection to a lawful decision by the competent authority and no continuing page 4 interest in the disputed domain name. Accordingly, we maintain that payment of any settlement amount is unwarranted and unjustified under these circumstances. 6. Discussion and Findings Paragraph 15(a) of the Rules requires that the Panel’s decision be made “on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. The Complainant must evidence each of the three elements required by paragraph 4(a) of the Policy in order to succeed on the Complaint with respect to each disputed domain name, namely that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. 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 name. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The applicable Top-Level Domain 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 3.1, section 1.11.1. The disputed domain name contains the ADM Trademark in its entirety, with the only addition of a hyphen and the word “trading”. The Panel finds the ADM Trademark is recognizable within the disputed domain name. The addition of a hyphen does not prevent a finding of identity or confusing similarity (see The Channel Tunnel Group Ltd. v John Powell, WIPO Case No. D2000-0038). The addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise), in this case “trading”, does not prevent a finding of confusing similarity under the first element. WIPO Overview 3.1, section 1.8. The Panel finds the mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 that 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 5 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 3.1, section 2.1. The Respondent stated in the Response to the Complaint, that the disputed domain name has never been used for any commercial, misleading, or bad-faith purpose, but had been merely registered and has remained inactive, with no website content, services, advertisements, or monetization of any kind associated with it. However, the Respondent has not provided any evidence for having rights or legitimate interests in the disputed domain name. The Complainant has not authorized, licensed, or permitted the Respondent to register or use the disputed domain name or to use the ADM Trademark. The Panel finds that there are no indications on record that the Respondent is commonly known by the disputed domain name. Further, the disputed domain name is not used for a bona fide offering of goods or services. Rather, the Complainant has provided evidence showing that the disputed domain name resolved to an active website prominently displaying the ADM Trademark and the ADM logo of the Complainant, where users had the option of entering data to create an account or login. The website linked to the disputed domain name does not accurately and prominently disclose the relationship, or rather the lack thereof, between the Respondent and the Complainant, thus creating the false impression that the Respondent might be an official and/or authorized provider for the Complainant’s services. This assessment is further supported by the nature of the disputed domain name. UDRP panels have found that domain names identical to a complainant’s trademark carry a high risk of implied affiliation. Even where a domain name consists of a trademark plus an additional term (at the second- or top-level), UDRP panels have largely held that such composition cannot constitute fair use if it effectively impersonates or suggests sponsorship or endorsement by the trademark owner. WIPO Overview 3.1, section 2.5.1. In view of the Panel, the composition of the disputed domain name, which incorporates the ADM Trademark together with the term “trading”, closely related to the Complainant’s (secondary) business, carries a risk of implied affiliation or association. 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 name. The Respondent has not (convincingly) 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 name such as those enumerated in the Policy or otherwise. 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. Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.1, section 3.1.4. Panels also have held that the use of a domain name for illegitimate activity (here, claimed impersonation/passing off) can never confer rights or legitimate interests on a respondent, such behavior is manifestly considered evidence of bad faith. WIPO Overview 3.1, section 3.4. page 6 Further, panels have found the following types of evidence to support a finding that a respondent has registered a domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s mark: (i) actual confusion, (ii) seeking to cause confusion (including by technical means beyond the domain name itself) for the respondent’s commercial benefit, even if unsuccessful, (iii) the lack of a respondent’s own rights to or legitimate interests in a domain name, (iv) redirecting the domain name to a different respondent-owned website, even where such website contains a disclaimer, (v) redirecting the domain name to the complainant’s (or a competitor’s) website, and (vi) absence of any conceivable good faith use. WIPO Overview 3.1, section 3.1.4. Moreover, paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. The Respondent stated in the Response to the Complaint, that the disputed domain name has never been used for any commercial, misleading, or bad-faith purpose, but had been merely registered and has remained inactive, with no website content, services, advertisements, or monetization of any kind associated with it. Notwithstanding the Respondent's contentions, the Panel has come to the following conclusions regarding the registration and use of the disputed domain name: In the present case, the disputed domain name incorporates the ADM Trademark in its entirety, whereas this trademark was registered years before the registration of the disputed domain name. Considering the distinctiveness and reputation of the ADM Trademark, Internet users may think the disputed domain name is connected to the Complainant and would resolve to a website related to the Complainant because the descriptive term “trading” used in the disputed domain name referring to the Complainant’s (secondary) business sector. Further, the Complainant has provided evidence showing that the disputed domain name previously resolved to an active website prominently displaying the ADM Trademark and the ADM logo of the Complainant, where users had the option of entering data to create an account or login. The option to enter data for users on a website where the Respondent is impersonating the Complainant suggests a fraudulent scheme, although the Complainant has not provided the Panel with clear supporting evidence. Further, the website linked to the disputed domain name did not accurately and prominently disclose the relationship, or rather the lack thereof, between the Respondent and the Complainant. Moreover, as shown above, the Respondent lacks rights or legitimate interests in the disputed domain name. The Panel finds that the Respondent has intentionally tried to impersonate the Complainant or, at least, attract, for commercial gain, Internet users to its websites by creating a likelihood of confusion with the Complainant and its ADM Trademark as to the source, sponsorship, affiliation or endorsement of the Respondent’s website. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes 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 name <adm-trading.pro> be transferred to the Complainant. /Manuel Wegrostek/ Manuel Wegrostek Sole Panelist Date: March 11, 2026

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

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