Westmore · UDRP DecisionAdm-de.com
The Panel ordered transfer of <adm-de.com>. It found the domain confusingly similar to the Complainant’s ADM mark, that the Respondent lacked rights or legitimate interests, and that the domain had been registered and used in bad faith as part of an email impersonation and payment-diversion scheme targeting a business partner of the Complainant.
The timeline behind adm-de.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 adm-de.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates a straightforward application of the UDRP to a trademark-plus-geographic-term domain used for business email impersonation. The domain’s composition supported targeting, while the documented attempt to redirect a substantial payment was decisive for both the absence of legitimate interests and 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 Archer-Daniels-Midland Company v. info jogetani Case No. D2026-0288 1. The Parties The Complainant is Archer-Daniels-Midland Company, United States of America (“United States” or “U.S.”), represented by Innis Law Group LLC, United States. The Respondent is info jogetani, Nigeria. 2. The Domain Name and Registrar The disputed domain name <adm-de.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 23, 2026. On January 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 27, 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 (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) 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 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 January 29, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 18, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 23, 2026. page 2 The Center appointed Yuri Chumak as the sole panelist in this matter on March 2, 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, Archer-Daniels-Midland Company (“ADM”), is a multinational agricultural processing and food ingredient corporation headquartered in the United States. Founded in 1902, the Complainant operates globally in the fields of agricultural processing, nutrition, food ingredients, and commodities trading. The Complainant owns numerous trademark registrations for the mark ADM, including registrations in multiple jurisdictions worldwide. By way of example, the Complainant is the owner of United States Trademark Registration No. 1,386,430 for ADM, registered on March 18, 1986; United States Trademark Registration No. 2,301,968 for ADM, registered on December 21, 1999; United States Trademark Registration No. 2,307,492 for ADM, registered on January 11, 2000; United States Trademark Registration No. 2,430,864 for ADM, registered on February 27, 2001; and United States Trademark Registration No. 2,766,613 for ADM, registered on September 23, 2003 (Annex 7). The Complainant further owns numerous ADM trademark registrations worldwide, including registrations in Canada, the European Union, China, Brazil, Singapore, and Viet Nam (Annex 8). The Complainant also operates numerous domain names incorporating its ADM mark, including <adm.com>, which resolves to its primary corporate website (Annex 6). The disputed domain name <adm-de.com> was registered on December 21, 2025. The Complainant has provided evidence showing that the disputed domain name has been used in connection with an email-based impersonation scheme targeting one of the Complainant’s business partners. In particular, emails were sent from an address using the disputed domain name that impersonated an employee of the Complainant and attempted to redirect payment to alternative bank account details provided by the sender (Annex 3). The Respondent is identified in the Registrar’s records as “info jogetani”, with an address in Nigeria. There is no evidence in the record that the Respondent has any affiliation with or authorization from the Complainant. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain name is confusingly similar to its ADM trademark because it incorporates the mark in its entirety with the addition of the geographic term “de”. The Complainant asserts that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is not affiliated with the Complainant and has not been authorized to use the ADM mark. The Complainant further contends that the disputed domain name has been registered and used in bad faith. In particular, the Complainant asserts that the Respondent used the disputed domain name as part of an impersonation and payment-diversion scheme involving fraudulent emails sent to one of the Complainant’s business partners. The Complainant requests transfer of the disputed domain name. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 entirety of the mark is reproduced 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. Although the addition of other terms here, “de” separated by a hypen, may bear on assessment of the second and third elements, t he Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. 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 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 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. 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 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. There is no evidence that the Respondent is commonly known by the disputed domain name or that it has used the disputed domain name in connection with a bona fide offering of goods or services. page 4 The record instead shows that the disputed domain name was used to send emails impersonating an employee of the Complainant and requesting that payment be redirected to alternative bank account details. Panels have held that the use of a domain name for illegitimate or illegal activity, including phishing, impersonation, or payment diversion fraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. 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. In the present case, the Panel notes that the disputed domain name incorporates the Complainant’s ADM mark in its entirety together with the term “de”, which appears to reference the Complainant’s German operations. This composition supports the inference that the Respondent was aware of the Complainant and its trademark when registering the disputed domain name, particularly noting how the disputed domain name has been used. The evidence shows that the disputed domain name was used to send emails impersonating an employee of the Complainant in connection with a request for payment of approximately USD 60,000 to alternative bank account details provided by the sender. Panels have held that the use of a domain name for illegitimate or illegal activity, including phishing, impersonation, or payment diversion fraud, constitutes bad faith. WIPO Overview 3.1, section 3.4. 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 Respondent registered and used the disputed domain name as part of an impersonation scheme targeting a business partner of the Complainant, using the name of the Complainant’s subsidiary and seeking to redirect payment to false bank account details provided by the sender. In these circumstances, the Panel concludes that the Respondent intentionally attempted to attract Internet users by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the communications. 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-de.com> be transferred to the Complainant. /Yuri Chumak/ Yuri Chumak Sole Panelist Date: March 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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