Westmore · UDRP DecisionLdc-fl.com
The Panel ordered transfer of <ldc-fl.com> to Louis Dreyfus Trademarks B.V. It found the domain confusingly similar to the Complainant’s LDC mark because it reproduced the mark in full, with the additional term “fl” and a hyphen. The Respondent lacked rights or legitimate interests because the domain was used for fraudulent emails impersonating an employee of the Complainant and attempting to divert a customer payment. The same conduct demonstrated the Respondent’s awareness of the Complainant and established registration and use in bad faith. The Respondent did not file a response.
The timeline behind ldc-fl.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 ldc-fl.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case is a clear example of targeted domain-based impersonation in which evidence of an attempted payment-diversion scheme resolved both the legitimate-interest and bad-faith inquiries. The domain’s inactive webpage at the time of decision did not neutralize its documented prior use for fraudulent email communications.
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 Louis Dreyfus Trademarks B.V. v. Ahmed Isa Case No. D2026-2945 1. The Parties The Complainant is Louis Dreyfus Trademarks B.V., Netherlands (Kingdom of the), represented by Inlex IP Expertise, France. The Respondent is ahmed isa, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <ldc-fl.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 July 4, 2026. On July 6, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 6, 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 July 8, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 28, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 6, 2026. The Center appointed Alissia Shchichka as the sole panelist in this matter on August 12, 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. page 2 4. Factual Background The Complainant is a Dutch company responsible for holding the intellectual property rights of Louis Dreyfus Company, a global merchant and processor of agricultural goods. Louis Dreyfus Company operates in more than 100 countries, accounts for approximately ten percent of global agricultural trade flows, and reported net sales of USD 50.6 billion in 2024. The Complainant has evidenced ownership of an extensive portfolio of LDC trademarks registered worldwide in more than 20 classes of goods and services. The Complainant also owns domain names incorporating its LDC trademark, including <ldc.com>, <ldcorp.com>, <ldcommodities.com>, <ldcbio.com>, and <ldcom.com>. The Complainant has evidenced to be the registered owner of trademark registrations, including, but not limited, to the following: - International Trademark registration No. 1729911, registered on April 7, 2023, for the word mark LDC, in classes 35, 40, and 44; and - Benelux trademark registration No. 1476212, registered on March 22, 2023, for the word mark LDC, in classes 35, 40, and 44. The aforementioned trademarks and domain names were registered before the disputed domain name <ldc- fl.com>, which was registered on June 5, 2026. As of the date of this Decision, the disputed domain name resolves to an inactive webpage. However, the Complainant has provided evidence that the disputed domain names was previously used to send emails impersonating an employee of the Complainant with the intent to commit financial fraud. The Respondent, according to the disclosed WhoIs information for the disputed domain name, is purportedly located in the United States. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for the transfer of the disputed domain name. Notably, the Complainant asserts that its LDC trademark is widely known. According to the Complainant, the disputed domain name is confusingly similar to the Complainant’s trademark, as it incorporates the trademark in its entirety. The addition of the letters “fl”, which may be understood as a geographical reference to Florida, does not prevent a finding of confusing similarity. In respect of the generic Top-Level Domain (“gTLD”) “.com”, which forms part of the disputed domain name, the Complainant requests that the Panel disregard it under the first element as it is a standard registration requirement. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name because (1) the Complainant has not licensed, authorized, or otherwise permitted the Respondent to use its LDC trademark or register the disputed domain name; (2) the Respondent is not commonly known by the disputed domain name and holds no corresponding trademark or other rights; and (3) the Respondent has used the disputed domain name to create a deceptive email address impersonating an actual employee of the Complainant and to confuse or deceive consumers for phishing purposes. According to the Complainant, such conduct cannot constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. page 3 Finally, the Complainant submits that the Respondent has registered and is using the disputed domain name in bad faith because (1) the Complainant’s trademark registrations significantly predate the registration of the disputed domain name; (2) the LDC trademark is widely known, and the Respondent was necessarily aware of the Complainant and its rights when registering the disputed domain name; and (3) the prior use of the disputed domain name in connection with email phishing schemes cannot be considered a bona fide offering of goods or services. The Complainant requests that the disputed domain name be transferred to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. The Respondent’s default in the case at hand does not automatically result in a decision in favor of the Complainant, however, paragraph 5(f) of the Rules provides that if the Respondent does not submit a response, in the absence of exceptional circumstances, the Panel shall decide the dispute solely based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel may draw such inferences from the Respondent’s failure to submit a response as it considers appropriate. 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, “fl”) and a hyphen 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. page 4 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. The Complainant has confirmed that the Respondent is not affiliated with the Complainant, or otherwise authorized or licensed to use the LDC trademark or to seek registration of any domain name incorporating the trademark. According to the Complainant, the Respondent has no trademark or trade name corresponding to the disputed domain name. There is no evidence showing that the Respondent has been commonly known by the disputed domain name. WIPO Overview 3.1, section 2.3. Based on the available record, the Panel finds that the Respondent is obviously not making a legitimate noncommercial or fair use of the disputed domain name without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. Indeed, the disputed domain name has been used to send fraudulent email communications reproducing the Complainant’s LDC trademark and logo and impersonating an actual employee of the Complainant. These emails sought to deceive one of the Complainant’s customers into changing bank details and urgently processing a payment in the mistaken belief that the instructions originated from the Complainant. UDRP panels have consistently held that the use of a domain name for illegal activity, including impersonation, passing off, phishing, or other forms of fraud, such as the attempted payment-diversion scheme at issue in this case, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Finally, the fact that the disputed domain name resolves to an inactive page does not alter the aforementioned conclusions. 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. Therefore, the Panel concludes that the Respondent does not have any rights or legitimate interests in the disputed domain name and the Complainant has met its burden under paragraph 4(a)(ii) of the Policy. 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. page 5 In the present case, the Panel notes that the Complainant’s well known LDC trademark substantially predates the Respondent’s registration of the disputed domain name. Therefore, the Panel finds that the Respondent knew or should have known of the Complainant’s trademark at the time of registering the disputed domain name. WIPO Overview 3.1, section 3.2.2. Moreover, the Respondent’s awareness of the Complainant and its trademark can be easily inferred from the use of the disputed domain name. By employing the disputed domain name to send fraudulent email communications featuring the Complainant’s LDC trademark and to impersonate the Complainant in fraudulent financial schemes, it is evident that the Respondent was aware of the business activities associated with the Complainant’s LDC trademark. Panels have held that the use of a domain name for illegal activity, here, fraudulent financial scheme, and impersonation/passing off 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 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 <ldc-fl.com> be transferred to the Complainant. /Alissia Shchichka/ Alissia Shchichka Sole Panelist Date: August 24, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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