Westmore · UDRP DecisionAdmsnutrition.com
The Panel ordered transfer of <admsnutrition.com>. It found the ADM mark recognizable in the domain despite the additional letter “s” and term “nutrition”; found no rebuttal to the Complainant’s prima facie case on rights or legitimate interests; and found bad-faith registration and use under the passive-holding doctrine. The bad-faith finding relied particularly on the reputation of ADM, the domain’s composition, the Respondent’s use of the Complainant’s North American headquarters address when registering the domain, and use of a privacy service.
The timeline behind admsnutrition.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 admsnutrition.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how passive holding can satisfy the bad-faith element when surrounding registration facts strongly indicate targeting. The unusually direct use of the trademark owner’s headquarters address supplied evidence of knowledge and suspected fraudulent intent even though the domain had no active website and no actual impersonation use was proven.
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. Akaba Rodriquez Case No. D2026-1958 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 Akaba Rodriquez, United States. 2. The Domain Name and Registrar The disputed domain name <admsnutrition.com> is registered with Name.com, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 6, 2026. On May 7, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 8, 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 (Domain Protection Service, Inc.) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 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 amended Complaints on May 15 and May 26, 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on May 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 16, 2026. Due to an administrative oversight, the Respondent was granted until June 29, 2026, to file a Response. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 30, 2026. page 2 The Center appointed Kathryn Lee as the sole panelist in this matter on July 3, 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 as an agribusiness in 1902, and has expanded to printing and publishing, financial and business management, fuel production, logistics, and research and development. The Complainant has used the initials ADM in connection with its business since 1923, and currently operates 800 facilities in 200 countries and has approximately 38,000 employees. In 2023, the Complainant’s worldwide net sales were USD 93 billion. The Complainant owns a number of trademark registrations for the ADM mark, including the following trademark registrations in the United States: Trademark Registration Number 1386430 registered on March 18, 1986, Trademark Registration Number 2766613 registered on September 23, 2003, and Trademark Registration Number 2301968 registered on December 21, 1999. Based on information from the Registrar, the Respondent is an individual with an address in the United States. The disputed domain name was registered on April 24, 2026, and does not resolve to any website with active content. 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 mark in which the Complainant has rights since the disputed domain name incorporates the Complainant’s ADM mark, and the ADM portion is the most prominent and recognizable portion of the disputed domain name. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name and confirms that it has not authorized or licensed rights to the Respondent in any respect. The Complainant further contends that there is no evidence of the Respondent’s use of, or demonstrable preparations to use, the disputed domain name in providing any bona fide offering of goods or services, nor any evidence that the Respondent has been commonly known by the disputed domain name or is making legitimate noncommercial or fair use of it. Finally, the Complainant contends that the disputed domain name was registered and used in bad faith. The Complainant contends that it has encountered a number domain names incorporating the ADM mark which have been used to defraud the Complainant and its partner businesses and that the disputed domain name will be used in the same way, specifically, to send emails impersonating the Complainant. Particularly, the Complainant suspects that the Respondent registered the disputed domain name shortly after the Complainant filed a UDRP complaint on April 17, 2026 against <admsnutri.com> which was used in a fraudulent email scheme impersonating the Complainant. However, the Complainant did not submit any evidence of the use of the disputed domain name, nor link to the registrants of the other ADM-based domain names, except that several of the prior domain names (including <admsnutri.com>) were also registered at Name.com, Inc. 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 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. Although the addition of other terms - here, the letter “s” and the term “nutrition” – may bear on assessment of the second and third elements, the Panel finds the addition of such terms 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. page 4 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. First, panels have found that ADM is a well-known and famous mark (see, for example, Archer-Daniels- Midland Company v. shimin li, Softvip, WIPO Case No. D2023-0034; Archer-Daniels-Midland Company v. zheng zi qiang, WIPO Case No. D2022-4929; and Archer-Daniels-Midland Company v. Truehost Cloud, Truehostcloud LTD, WIPO Case No. D2025-0997). Further, based on information from the Registrar, the Respondent used the actual address of the Complainant’s North American Headquarters in Decatur, IL when registering the disputed domain name. This clearly shows that the Respondent knew of the Complainant and the ADM mark when registering the disputed domain name and strongly suggests that the Respondent intended to use it for some fraudulent purpose. There is no evidence that the disputed domain name has ever been used. Nonetheless, 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 (incorporating the term “nutrition” which is one of the Complainant’s business areas), and the use of the privacy service, 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 <admsnutrition.com> be transferred to the Complainant. /Kathryn Lee/ Kathryn Lee Sole Panelist Date: July 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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