Westmore · UDRP DecisionAdmlgroup.org
The Panel ordered transfer of <admlgroup.org>. It found the domain confusingly similar to the Complainant’s ADM trademark because ADM remained clearly recognizable despite the addition of the letter “l” and the word “group.” The Respondent had no rights or legitimate interests because the domain was used for emails and documents impersonating the Complainant in an apparent fraudulent commodities-procurement scheme. The same conduct, together with the reputation and long-standing use of the ADM mark, established registration and use in bad faith.
The timeline behind admlgroup.org
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The case illustrates that a domain need not host an active website to support transfer where it is used as email infrastructure for impersonation. The combination of a recognizable trademark, a corporate-sounding term, and transaction documents incorporating authentic company details provided a strong factual basis for findings under the second and third UDRP elements.
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 (ADM) v. Aaliyah M Byrne Case No. D2026-1487 1. The Parties The Complainant is Archer-Daniels-Midland Company (ADM), United States of America (“United States”), represented by Innis Law Group LLC, United States. The Respondent is Aaliyah M Byrne, United Kingdom. 2. The Domain Name and Registrar The disputed domain name <admlgroup.org> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 9, 2026. On April 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 13, 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) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 14, 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 the same date. 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 April 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 6, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 8, 2026. page 2 The Center appointed Syed Naqiz Shahabuddin as the sole panelist in this matter on May 18, 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 following summary sets out the uncontested factual submission made by the Complainant: 4.1 Founded in 1902, the Complainant is one of the world’s most premier agribusinesses. The Complainant serves 200 countries, owns more than 800 facilities worldwide, employs over 38,000 people, and in 2023, recorded worldwide net sales of USD93 billion. 4.2 Although the Complainant was originally a food and ingredients company, its business areas also now include printing and publishing; financial and business management services; fuel production, including bioethanol and biodiesel; logistics services (agricultural storage and transportation services); and research and development services. 4.3 The Complainant provides financial services through ADM Investor Services, Inc. (“ADMIS”) and its many branches throughout the world. ADMIS, which is located in Chicago, Illinois, has been a leader in the futures brokerage industry for over 40 years. Consumers can use ADMIS’s services online to make bids on commodities, such as grains, and to learn more about the futures brokerage industry so that they can make informed decisions to better their portfolios. Customers can also use ADMIS’s services online to gain access to its various trading platforms, stock quotes, stock charts, and other stock related news. 4.4 The Complaint is known by the initials of its corporate name and trademark “ADM” (the “Trademark”). The Trademark was adopted and has been continuously used since at least as early as 1923. Today, the Trademark is largely recognizable due to the international nature of the Complainant’s business, as well as the online presence which the Complainant maintains. 4.5 The Complainant owns numerous trademark registrations for the Trademark and variations thereof on a worldwide basis for a wide range of goods and services including chemicals, industrial oils, mode of transport and transportation, processed foods, staple foods, natural agricultural products, market research, financial and investment services and on-line software. The table below sets out a list of some of the Complainant’s Trademark registrations in the United States: Jurisdiction Registration Number Date of Registration Class of Goods / Services United States 1,386,430 March 18, 1986 1, 4, 12, 16, 29, 30, 31, 33, 39 United States 2,307,492 January 11, 2000 35, 36, 40, 42 United States 2,766, 613 September 23, 2003 16, 35, 36, 42 4.6 The Complainant maintains its online global presence via its various websites. For example, the Complainant maintains a presence online through its main website “www.adm.com”. The website allows consumers to read about the history of the Complainant, its products and services and provides consumers with the latest news on the Complainant. The website and the domain name are an integral part of the Complainant’s business as it allows consumers and business associates from around the world to learn about and communicate with the Complainant as well as to conduct business with the Complainant from anywhere in the world. page 3 4.7 The Complainant submitted this Complaint after receiving notice of the following matters, purportedly orchestrated or devised by the Respondent: (a) On or about March 11, 2026, the Complainant received an email from a Complainant’s business partner, complaining of certain individuals fraudulently representing themselves as representatives of the Complainant and attempting to deceive and scam local businesses. (b) The email attached a letter dated March 9, 2026, purportedly signed by Complainant’s purported officials. The letter alleged that the business partner was authorized to purchase a large quantity of goods on behalf of the Complainant which the Complainant intended to import to the United States and used the Complainant’s Trademark and logo, the address of the Complainant’s North American Headquarters and the Complainant’s main web address. (c) The letter stated that the Complainant was “completely out of stock” and that the Complainant would arrange payment to Coco Delight. The letter was stated to “constitute, direct, substantiate unconditional and irrevocable obligations” to the Complainant and that the Complainant would “not be relieved from these obligations or any part thereof for any reason”. The letter appeared to be signed by Complainant’s purported officials. The letter also referred to a legitimate employee of the Complainant. (d) The letter was accompanied by a purchase order dated March 9, 2026 for the Complainant to purchase USD 600,000 worth of Acerola Oil from Coco Delight. The amount was to be paid “100% against delivery”. Like the authorization letter, the purchase order was signed by a Complainant’s officials. (e) Both documents listed the company as “Archer Daniels Midland, Inc”. (f) Additionally, an email dated March 7, 2026, was sent to Coco Delight from the address “[...]@admlgroup.org” which displayed a purported email from a diplomatic to the email address linked to the disputed domain name. The email stated that the it was “glad assisting your company in facilitating your project plans in Sri Lanka” and advised that the diplomatic office“carry out the test analyses on the product (Acerola Oil Extract) of which Archer - Daniels- Midland Group ADM intend to be Exporting to the [...] from Sri Lanka”. It also gave details of an individual in Sri Lanka who would carry out the testing and stated that “[t]he supplier should immediately move to hand over the sample as soon as possible without further delay to the following address details below[...].” 4.9 Based on the Whois record, the disputed domain name was registered on October 15, 2025. 4.10 As of April 3, 2026, the disputed domain name resolves to an inactive website located at “www.admlgroup.org”. 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. Notably, the Complainant contends, inter alia, as follows; 5.1 The Complainant asserts that the disputed domain name is identical to the Trademark for the following reasons: (a) the disputed domain name incorporates the Trademark in its entirety. page 4 (b) the addition of the letter “l” and the word “group” do not distinguish the disputed domain name from the Trademark. They remain phonetically similar. (c) Any individual who encounters correspondence from the email address associated with the disputed domain name would be reasonably misled into believing that the communications are coming from, or are somehow affiliated with the Complainant, as evidenced by the Complainant’s business partner continued correspondence and involvement with the sender, “[...]@admlgroup.org”. (d) The word “group” was likely chosen to appear as a legitimate domain name of the Complainant given that the Complainant owns and operates numerous domain names for its various business units and global presence. (e) Given the notoriety of the Complainant and its international presence, the inclusion of ADM with the word “group” will lead the average consumer to believe that the disputed domain name belongs to the Complainant. 5.2 The Complainant further contends that the Respondent does not have any rights or legitimate interests in the disputed domain name because: (a) the Respondent is not commonly known by the disputed domain name. (b) the Complainant has built up international goodwill and reliability in the Trademark, which is now well- known and famous among its consumers. (c) the Respondent is attempting to fraudulently impersonate the Complainant and deceive a potential business partner of the Complainant by using the disputed domain name. Hence, the Respondent is not making a legitimate non-commercial or fair use of the disputed domain name without intent for commercial gain and neither is the Respondent making preparations to use the disputed domain name with a bona fide offering of goods or services. 5.3 The Complainant further contends that the Respondent registered and uses the disputed domain name in bad faith and relies on the following: (a) given the reputation and distinctive nature of the Trademark, the Respondent was aware of the Complainant and its Trademark when it sought to register the disputed domain name. (b) the Respondent registered the disputed domain name and subsequently used the email address “[...]@admlgroup.org” to impersonate the Complainant and the Complainant’s employee, to target and to take advantage of the business partner in the manner described above. (c) the disputed domain name was deliberately chosen to be used as an email address coupled with the names of legitimate employees of the Complainant and the Trademark when approaching potential targets such as the business partner. (d) the Respondent intended to trade on the goodwill of the Complainant’s fame, trademarks, reputation, and online presence through the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 5 6. Discussion and Findings In order to succeed in its Complaint, the Complainant is required to establish the following elements set out under paragraph 4(a) of the Policy: (a) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (b) that the Respondent has no rights or legitimate interest in respect of the disputed domain name; and (c) that 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 Panel is satisfied with the evidence adduced by the Complainant of various registrations of the Trademark. Although the addition of the letter “l” and the word “group” may bear on the assessment of the second and third elements, the Panel finds that these additions do not prevent a finding of confusing similarity between the disputed domain name and the Trademark for purposes of the Policy. WIPO Overview 3.1, section 1.8. The disputed domain name remains confusingly similar because the Trademark is clearly recognizable within it and constitutes its dominant element. The Panel finds that the entirety of the Trademark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the Trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 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. page 6 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. The evidence indicates that the Respondent used the disputed domain name to impersonate the Complainant by sending emails and documents to the Complainant’s customers or potential customers in an apparent attempt to fraudulently obtain tradable commodities. As part of this scheme, the documents bore the names and signatures of the Complainant’s senior management and the Consulate General of the United States Embassy in Sri Lanka. This conduct plainly does not give rise to any rights or legitimate interests, nor does it constitute legitimate non-commercial or fair use without intent for commercial gain. Panels have held that using a domain name for illegal activity, including the alleged fraud here, 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. 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. In the present case, the Panel notes the following: (a) the disputed domain name comprises the Trademark in its entirety in circumstances where the Trademark has gained substantial reputation and goodwill. (b) the disputed domain name resolves to an inactive website. (c) the disputed domain name was only registered more than a century after the Trademark was first used by the Complainant in 1923 and subsequently, registered worldwide by the Complainant. (d) the disputed domain name was allegedly used by the Respondent as part of an elaborate impersonation scheme to fraudulently procure tradable commodities from a Sri Lankan company. In particular: (i) the disputed domain name was used as an email address in communications directed to the target company; and (ii) those emails included fabricated correspondence purportedly issued by the Complainant’s senior management and diplomats. Panels have held that the use of a domain name for illegal activity, including the alleged fraud here, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, therefore, 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. page 7 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 <admlgroup.org> be transferred to the Complainant. /Syed Naqiz Shahabuddin/ Syed Naqiz Shahabuddin Sole Panelist Date: May 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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