Westmore · UDRP DecisionAmeren-corp.com, Amerenus.com
The Panel ordered the transfer of <ameren-corp.com> and <amerenus.com> to Ameren Corporation. It consolidated the disputes against the nominally different registrants after finding common control, including registration within three months, incorporation of the AMEREN mark, and use in a common fraudulent email scheme impersonating the same Ameren employee. The Panel found confusing similarity, no rights or legitimate interests, and bad-faith registration and use.
The timeline behind ameren-corp.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 ameren-corp.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how email-based impersonation can determine both the rights-or-legitimate-interests and bad-faith elements even when the domains display no substantive website. It also shows that coordinated phishing evidence may support consolidation of nominally different registrants where common control and procedural fairness are established.
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 Ameren Corporation v. Lucky Maxwell, Santander International, and Patrick Moore, MEI Rigging and Crating Case No. D2026-0481 1. The Parties The Complainant is Ameren Corporation, United States of America (“United States”), represented by Greenberg Traurig, LLP, United States. The Respondents are Lucky Maxwell, Santander International, Nigeria, and Patrick Moore, MEI Rigging and Crating, United States. 2. The Domain Names and Registrars The disputed domain name <ameren-corp.com> is registered with Hostinger Operations, UAB; and the disputed domain name <amerenus.com> is registered with NameCheap, Inc. (collectively, the “Registrars”). The disputed domain names <ameren-corp.com> and <amerenus.com> will hereinafter be referred to as the “Disputed Domain Names”. 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 5, 2026. On February 5, 2026, the Center transmitted by email to the Registrars requests for registrar verification in connection with the Disputed Domain Names. On February 5 and 6, 2026, 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 (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf; and REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 6, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting that the Complainant either file separate Complaints 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 the Disputed Domain Names are under common control. The Complainant filed an amended Complaint on February 11, 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on February 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 5, 2026. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on March 6, 2026. The Center appointed Lynda M. Braun as the sole panelist in this matter on March 10, 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 Formed in 1997 through the merger of CIPSCO Incorporated, CILCO Inc. and Illinois Power Company, and Union Electric Company of St. Louis, the Complainant operates as an energy holding company with rate- regulated utility subsidiaries that deliver electricity and natural gas to residential, commercial, and industrial customers across approximately 64,000 square miles in central and eastern Missouri, United States and much of Illinois, United States. The name “Ameren” is the combination of the words “American” and “energy.” The Complainant owns registered trademarks through the United States Patent and Trademark Office (“USPTO”), including, but not limited to: AMEREN, United States Registration No. 3,914,523, registered on February 1, 2011, with a first use in commerce of 1997, in International Class 39; AMEREN (stylized), United States Registration No. 2,162,874, registered on June 2, 1998, in International Class 39; AMEREN ILLINOIS (stylized), United States Registration No. 3,952,591, registered on April 26, 2011, in International Class 39; and AMEREN MISSOURI (stylized), United States Registration No. 3,952,589, registered on April 26, 2011, in International Class 39 (hereinafter collectively referred to as the “AMEREN Mark”). The Ameren Mark serves as a unique source identifier for the Complainant’s goods and services. The Complainant owns and operates the domain name <ameren.com> and has done so since 1995. The Complainant’s domain name resolves to its official website at “www.ameren.com”, which provides general information about the Complainant and its services and prominently displays the Ameren Mark. In addition, website visitors can create and manage accounts to pay bills, report outages, and sign up for the Complainant’s services. The Complainant also uses its domain name for all of its official email addresses. The disputed domain name <ameren-corp.com> was registered on November 29, 2025 and the disputed domain name <amerenus.com> was registered on August 13, 2025. The Disputed Domain Names resolve to error landing pages with no substantive content. The Respondents used the Disputed Domain Names in a fraudulent scheme in which the Respondents configured the Disputed Domain Names for email functions and created email addresses incorporating the Disputed Domain Names to impersonate one of the Complainant’s employees and send fraudulent emails to the Complainant’s customers in an attempt to obtain lines of credit and make large purchases in the Complainant’s name. The Complainant’s customers were thus led to believe that they were interacting with a genuine representative of the Complainant. On December 23, 2025, the Complainant’s counsel sent correspondence to the Registrars of the Disputed Domain Names, advising them of the abusive nature of the Disputed Domain Names. The Registrars agreed that use of the Disputed Domain Names was abusive and confirmed suspension of the Disputed Domain Names. page 3 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. Notably, the Complainant contends that: - the Disputed Domain Names are confusingly similar to the Complainant’s trademark because the Disputed Domain Names contain the AMEREN Mark, joined by a hyphen to the term “corp”, then followed by the generic Top-Level Domain (“gTLD”) “.com” in one disputed domain name; and in the other disputed domain name, followed by the term “us” and the gTLD “.com”; - the Respondents have no rights or legitimate interests in respect of the Disputed Domain Names because, among other things, the Complainant has not authorized the Respondents to register a domain name containing the AMEREN Mark, and the Respondents are not making a bona fide offering of goods or services through use of the Disputed Domain Names; and - the Disputed Domain Names were registered and used in bad faith because, among other things, the Respondents used the Disputed Domain Names in email addresses to impersonate one of the Complainant’s employees and send fraudulent emails to the Complainant’s customers. The Complainant seeks the transfer of the Disputed Domain Names from the Respondents to the Complainant in accordance with paragraph 4(i) of the Policy. B. Respondents The Respondents did not reply to the Complainant’s contentions 6. Discussion and Findings 6.1. Preliminary Issue – Consolidation: Multiple Respondents The Complainant has requested the consolidation of the Respondents in this proceeding. Pursuant to paragraph 3(c) of the Rules, “[t]he complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder.” Where a complaint is filed against multiple respondents, UDRP panels look at whether (i) the 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 Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.2. Procedural efficiency would also underpin panel consideration of such a consolidation scenario. See Speedo Holdings B.V. v. Programmer, Miss Kathy Beckerson, John Smitt, Matthew Simmons, WIPO Case No. D2010-0281. The disputed domain name registrants did not comment on the Complainant’s request. The Panel finds that the Disputed Domain Names are subject to common control for the following reasons: the Disputed Domain Names both contain the Complainant’s AMEREN Mark; the Disputed Domain Names were both registered within three months of each other; and the Disputed Domain Names were both used as part of a common phishing scheme where they were used to create fraudulent email addresses impersonating the same employee of the Complainant. These common elements constitute strong evidence that the Disputed Domain Names are subject to common control. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to either 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. page 4 6.2. Substantive Issues Paragraph 4(a) of the Policy requires that the Complainant prove the following three elements in order to prevail in this proceeding: (i) the Disputed Domain Names are 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 Names; and (iii) the Disputed Domain Names were registered and are being used in bad faith. A. Identical or Confusingly Similar Paragraph 4(a)(i) of the Policy requires a two-fold inquiry: a threshold investigation into whether a complainant has rights in a trademark, followed by an assessment of whether the disputed domain name is identical or confusingly similar to that trademark. The Panel concludes that in the present case, the Disputed Domain Names are confusingly similar to the AMEREN Mark, differing in one of the Disputed Domain Names with the term “corp” joined by a hyphen to the disputed domain name, followed by the gTLD “.com”; and the other disputed domain name containing the term “us” followed by the gTLD “.com”. 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 Names. See WIPO Overview 3.1, section 1.7. It is uncontroverted that the Complainant has established rights in the AMEREN Mark based on its registered trademarks for the AMEREN Mark in the USPTO. The registration of a mark satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case. As stated in section 1.2.1 of the WIPO Overview 3.1, “[w]here the complainant holds a nationally or regionally registered trademark or service mark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case”. The Panel thus finds that the Complainant satisfied the threshold requirement of having trademark rights in the AMEREN Mark. The test for confusing similarity involves a side-by-side comparison of the disputed domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name. Here, the AMEREN Mark is recognizable within the Disputed Domain Names. As stated 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 [...] would not prevent a finding of confusing similarity under the first element”. Thus, the addition of the terms “corp” or “us” to the Complainant’s AMEREN Mark in the Disputed Domain Names does not prevent a finding of confusing similarity. See e.g., Allianz Global Investors of America, L.P. and Pacific Investment Management Company (PIMCO) v. Bingo-Bongo, WIPO Case No. D2011-0795; and Hoffmann-La Roche Inc. v. Wei-Chun Hsia, WIPO Case No. D2008-0923. Moreover, it is well established that a disputed domain name that wholly incorporates a trademark will normally be considered confusingly similar to that trademark for purposes of the Policy despite the addition of a hyphen (as in the disputed domain name <ameren-corp.com>). The presence or absence of punctuation marks such as hyphens cannot on their own avoid a finding of confusing similarity. See Six Continents Hotels, Inc. v. Helen Siew, WIPO Case No. D2004-0656. Finally, the addition of a gTLD such as “.com” in a domain name is a technical requirement. Thus, it is well established that, as here, such element may typically be disregarded when assessing whether a domain name is identical or confusingly similar to a trademark. See WIPO Overview 3.1, section 1.11.1. Thus, the Panel finds that the Disputed Domain Names are confusingly similar to the Complainant’s AMEREN Mark. Based on the available record, the Panel finds that the first element of the Policy has been established. page 5 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. In this case, given the facts as set out above, the Panel finds that the Complainant has made out a prima facie case. The Respondent has not submitted any arguments or evidence to rebut the Complainant’s prima facie case. Furthermore, the Complainant has not authorized, licensed or otherwise permitted the Respondent to use its AMEREN Mark. Nor does the Complainant have any type of business relationship with the Respondent. There is also no evidence that the Respondent is commonly known by the Disputed Domain Names or by any similar name, nor any evidence that the Respondent was using or making demonstrable preparations to use the Disputed Domain Names in connection with a bona fide offering of goods or services. See Policy, paragraph 4(c). Further, based on the Respondent’s use made of the Disputed Domain Names to impersonate one of the Complainant’s employees and configure emails to perpetuate a fraudulent email scheme does not confer rights or legitimate interests on the Respondent. See WIPO Overview 3.1, section 2.13.1 (“Panels have categorically held that the use of a domain name for illegal activity (e.g., [...] passing off, or other types of fraud) can never confer rights or legitimate interests on a respondent.”). See also Agricola Industrial Lo Valledor AASA v. Name Redacted, WIPO Case No. D2021-0402 (respondent’s use of a domain name for a fraudulent scheme is not a bona fide offering and constitutes prima facie evidence that the respondent lacks rights or legitimate interests). This is precisely what occurred here, where the Respondent sent fraudulent emails created from the Disputed Domain Names to the Complainant’s customers as part of a phishing scheme. In sum, the Panel concludes that the Complainant has established an unrebutted prima facie case that the Respondent lacks rights or legitimate interests in the Disputed Domain Names. The Panel finds that the Respondent is using the Disputed Domain Names for commercial gain with the intent to mislead and defraud the Complainant’s customers by incorporating the Disputed Domain Names into fraudulent emails sent by the Respondent to those customers in the name of an actual employee of the Complainant. Such use cannot conceivably constitute a bona fide offering of a product or service within the meaning of paragraph 4(c)(i) of the Policy. The Panel concludes that nothing on the record before it would support a finding that the Respondent is making a legitimate noncommercial or fair use of the Disputed Domain Names. Based on the available record, the Panel finds that 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. 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. The Panel finds that based on the record, the Complainant has demonstrated the existence of the Respondent’s bad faith registration and use of the Disputed Domain page 6 Names, 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. Panels have held that the use of a domain name for illegal activity constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds that the Respondent’s registration and use of the Disputed Domain Names constitutes bad faith under the Policy due to the Respondent’s use of a fraudulent email scheme in which the Respondent, impersonating one of the Complainant’s employees, sent emails with addresses incorporating the AMEREN Mark to the Complainant’s customers, requesting lines of credit. See WIPO Overview 3.1, section 3.1.4 (use of a domain name for per se illegitimate activity such as passing off is considered evidence of bad faith). See also Stichting BDO v. Contact Privacy Inc. Customer 7151571251 / gregory Motto, WIPO Case No. D2022-2023 (finding use of an email address incorporating the disputed domain name to fraudulently obtain payment of invoices to be evidence of bad faith pursuant to paragraph 4(b)(iv) of the Policy for intentionally misleading and confusing the public into believing that the Respondent was associated and/or affiliated with the Complainant). Thus, the Panel concludes that the Respondent used the Disputed Domain Names as part of an illegal scheme to defraud the Complainant’s customers. Such conduct demonstrates the Respondent’s bad faith and is precisely the conduct that the Policy aims to proscribe. The Panel also finds that the Respondent had actual knowledge of the Complainant and its rights in the AMEREN Mark when registering the Disputed Domain Names, emblematic of bad faith registration and use. It strains credulity to believe that the Respondent did not know of the Complainant or its AMEREN Mark when registering the Disputed Domain Names, as evidenced by the unique nature of the Complainant’s name and the inclusion of the AMEREN Mark in fraudulent emails. Thus, the Panel finds that in the present case, the Respondent had the Complainant’s AMEREN Mark in mind when registering and using the Disputed Domain Names. Further, the Panel concludes that the Respondent’s registration and use of the Disputed Domain Names was an attempt to disrupt the Complainant’s business for commercial gain. See Newegg Inc. v. Nicole Alex and Alexander Ethan, WIPO Case No. D2019-2740 (registration of disputed domain names was likely to have been made in an attempt to receive commercial gain from their exploitation). The Panel additionally finds that the Respondent’s use of the Disputed Domain Names was also highly likely to confuse the Complainant’s customers into incorrectly believing that the Respondent was authorized, sponsored by, or affiliated with the Complainant. Based on the available record, the Panel finds that the third element of the Policy has been established. 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 <ameren-corp.com> and <amerenus.com> be transferred to the Complainant. /Lynda M. Braun/ Lynda M. Braun Sole Panelist Date: March 23, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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