Westmore · UDRP DecisionAmericanairlinetx.com
The Panel ordered transfer of <americanairlinetx.com>. It found the domain confusingly similar to the AMERICAN AIRLINES mark because it incorporated the mark without its final letter and added “tx”. The Respondent did not rebut the Complainant’s prima facie showing regarding rights or legitimate interests. Bad faith was established from the totality of circumstances, including the mark’s reputation, the Texas-related composition of the domain, passive holding, seemingly false registration details, use of the name of a Complainant officer, and configured MX records suggesting a likely fraudulent-email purpose.
The timeline behind americanairlinetx.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 americanairlinetx.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a close typographical variation combined with a geographically meaningful abbreviation can support both confusing similarity and an inference of deliberate targeting. It also shows that passive holding may establish bad faith when reinforced by a well-known mark, apparently false or impersonating registration details, and MX records suggesting possible email misuse.
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 American Airlines, Inc. v. Name Redacted Case No. D2026-1650 1. The Parties The Complainant is American Airlines, Inc., United States of America (“United States”), represented by Greenberg Traurig, LLP, United States. The Respondent is Name Redacted. 1 2. The Domain Name and Registrar The disputed domain name <americanairlinetx.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 17, 2026. On April 17, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 20, 2026, the Registrar transmitted by email to the Center its verification response, confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that 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 21, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 12, 2026. 1 The Respondent appears to have used the name and/or contact details of a third party when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this Decision. However, the Panel has attached as Annex 1 to this Decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in these proceedings, and has indicated Annex 1 to this Decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST 12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 The Center appointed Michelle Brownlee as the sole panelist in this matter on May 22, 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 is a company based in Texas, United States that is engaged in the business of air travel. The Complainant has been doing business under the trademark AMERICAN AIRLINES since as early as April 1934. The Complainant owns registrations for the AMERICAN AIRLINES mark in the United States and more than 75 other countries. The Complainant owns the following registrations, among others: United States Registration Number 514294 for AMERICAN AIRLINES in connection with air transport of passengers and freight in International Class 39, registered on August 23, 1949; United States Registration Number 4939082 for AMERICAN AIRLINES in connection with services in International Classes 35, 37, 39, 41 and 43, registered on April 19, 2016; and United States Registration Number 5279167 for AMERICAN AIRLINES in connection with goods in International Class 9 and services in International Class 38, registered on September 5, 2017. The Complainant created a website in 1998 at the domain names <americanairlines.com> and <aa.com> and continues to operate the website using those domain names. The Respondent registered the disputed domain name on May 1, 2025. There is no content posted on the website at the disputed domain name. 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 that the disputed domain name is confusingly similar to the Complainant’s AMERICAN AIRLINES trademark, the Respondent has no rights to or legitimate interests in respect of the disputed domain name, and the Respondent has registered and is using the disputed domain name in bad faith. In particular, the Complainant relies on Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003 to argue that bad faith can be found where the Respondent is engaged in passive holding of the disputed domain name registration, the Complainant’s trademark is extremely well known, and the Respondent has provided no evidence of any actual or contemplated good faith use of the disputed domain name. The Complainant notes that the Respondent appears to have used false contact information, using a non-existent town name of “DFW Airport”, which is the name of an airport in Texas, and using the name of an officer of the Complainant. The Complainant also argues that bad faith is demonstrated by the fact that the Respondent has set up mail exchange (“MX”) records, which indicates a likelihood that the Respondent has used or is preparing to use the disputed domain for fraudulent email communications such as phishing. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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 Panel finds the mark is recognizable within the disputed domain name. The disputed domain name includes the Complainant’s AMERICAN AIRLINES mark without its last letter, combined with the letters “tx”. 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, “tx”, may bear on assessment of the second and third elements, the 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. 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 Respondent registered the disputed domain name, which is confusingly similar to the Complainant’s well-known AMERICAN AIRLINES trademark. This trademark is so well known that it is unlikely that the Respondent would not have been aware of it. Because the page 4 Complainant’s headquarters are in Texas, the addition of the letters “tx”, which is the postal abbreviation for the state of Texas, would appear to be designed to further evoke a connection with the Complainant. It is difficult to imagine a good faith use of the disputed domain name by any party other than the Complainant. Further, there are additional indications of bad faith in this case. The Respondent seemingly used false contact information in the registration details of the disputed domain name, including the name of an officer of the Complainant, and the Respondent set up MX records, suggesting a likely intention to use the disputed domain name as part of a fraudulent email scheme. 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. Panels have found that the non-use of a domain name 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, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the reputation of the Complainant’s trademark, the composition of the disputed domain name, and the Respondent’s use of false contact details, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of 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 <americanairlinetx.com> be transferred to the Complainant. /Michelle Brownlee/ Michelle Brownlee Sole Panelist Date: June 5, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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