Westmore · UDRP decision
WIPO · Case No. D2026-3714

Admfarms.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <admfarms.com> to Archer-Daniels-Midland Company. It found the domain confusingly similar to the Complainant’s registered ADM marks, that the Respondent lacked rights or legitimate interests, and that the domain had been registered and used in bad faith to impersonate a Complainant employee in emails seeking to order golf carts. The Respondent did not file a response.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-10-02
Panelist(s)
Raj Sachdev
Complainant
Archer-Daniels-Midland Company
Respondent
Ashley Marshall
Disputed domain(s)
admfarms.com
Citation weightrelies on 10 authorities
Domain history UDRP Intelligence

The timeline behind admfarms.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 admfarms.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of admfarms.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how a domain combining a trademark with a term associated with the trademark owner’s business can support an impersonation scheme. The decisive evidence went beyond the domain’s composition: the associated emails purported to come from a legitimate employee and used the Complainant’s logo and genuine office address while seeking an order of goods.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registration and use in bad faithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-10-02
Panel
Raj Sachdev
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Archer-Daniels-Midland Company v. Ashley Marshall Case No. D2026-3714 1. The Parties The Complainant is Archer-Daniels-Midland Company, United States of America (“United States” or “U.S.”), represented by Innis Law Group LLC, United States. The Respondent is Ashley Marshall, United States. 2. The Domain Name and Registrar The disputed domain name <admfarms.com> is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 19, 2026. On August 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 22, 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 (Registration Private) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 25, 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 amended Complaint on August 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 August 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 16, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 21, 2026. The Center appointed Raj Sachdev as the sole panelist in this matter on September 24, 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 Archer-Daniels-Midland Company, widely known as ADM, was founded in 1902 and maintains a global presence. In 2023, its reported worldwide net sales were USD 93 billion. Founded as a linseed crushing business, today it operates in a number of sectors. It holds numerous trademarks worldwide for ADM (“ADM Marks”) including: U.S. Trademark Registration No. Mark Class(es) Date of Registration 1,386,430 ADM 1, 4, 12, 16, 29, 30, 31, and 39 March 18, 1986 2,766,613 ADM 16, 35, 36, and 42 September 23, 2003 2,301,968 ADM 5 December 21, 1999 Various panels have found that the ADM mark is well-known (see Archer-Daniels-Midland Company v. Archer Daniels, WIPO Case No. D2025-2594 ; and Archer-Daniels-Midland Company v. Terry A Dunlap, Terry Dunlap, WIPO Case No. D2025-3923 ). The disputed domain name was registered on February 26, 2026. The Complainant submitted evidence of use of an email address associated with the disputed domain name to send emails about items from a third party. 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 ADM Marks because it contains the ADM Mark. The Complainant also contends that the Respondent is not commonly known by the disputed domain name, and has never engaged in any bona fide commercial activity in connection with the disputed domain name. The Complainant further contends that the Respondent has no rights or legitimate interests in the disputed domain name and has registered and used the disputed domain name in bad faith to perpetrate scams and impersonate the Complainant. The Complainant has provided evidence that the disputed domain name was used for sending fraudulent emails impersonating an employee of 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, to succeed the Complainant must satisfy the Panel that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name was 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. page 3 The Complainant has shown rights in respect of the ADM Marks for the purposes of the Policy through its trademark registrations including the United States registrations referenced in the Factual Background section above (see WIPO Overview 3.1, section 1.2.1). The ADM mark is entirely reproduced within the disputed domain name along with the addition of “farms”. As is the case here, where a domain name incorporates the entirety of a trademark, or where at least a dominant feature of the relevant mark is recognizable in the disputed domain name, the disputed domain name will normally be considered confusingly similar to that mark (see WIPO Overview 3.1, section 1.7). Although the addition of another term, here, “farms,” 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 (see WIPO Overview 3.1, section 1.8; Archer-Daniels-Midland Company v. Terry A Dunlap, Terry Dunlap, WIPO Case No. D2025-3923 ; Archer- Daniels-Midland Company v. James Harrison, WIPO Case No. D2025-4270 ; and Lennar Pacific Properties Management, Inc., Lennar Corporation v. Registration Private, Domains By Proxy, LLC / IAutomation Contractors, WIPO Case No. D2022-1768). Accordingly, the disputed domain name is confusingly similar to the ADM Marks for the purposes of the Policy. 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 (see 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 submitted a response and accordingly 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. There is no evidence that the Respondent is commonly known by the disputed domain name. Further, there is no evidence of any bona fide offering of goods or services, or legitimate noncommercial use. Panels have held that the use of a domain name for illegitimate or illegal activity such as phishing/identity theft, passing off, or other types of fraud can never confer rights or legitimate interests on a respondent (WIPO Overview 3.1, section 2.13.1). Specifically, panels have held that illegal activity and a deceptive use of the disputed domain name such as impersonation cannot confer such rights (see Archer-Daniels-Midland Company v. adm corps, WIPO Case No. D2024-3086; Lonza Ltd v. Geral Gera, SEGLINK, WIPO Case No. D2025-1342; CGI Inc. v. Christophe Schmidt, WIPO Case No. D2024-5269; and SESSUN v. Samuel Williams Williams, WIPO Case No. D2023-2132). The Complainant has submitted evidence showing the disputed domain name was used for impersonation of an employee of the Complainant, specifically, that an email address associated with the disputed domain name [...]@admfarms.com was used by the Respondent to send emails about purchasing golf carts purported to be an order from a legitimate employee of the Complainant. 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. In the present case, the Panel notes that the Respondent has registered and used the disputed domain name in bad faith under paragraph 4(b) of the Policy. 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 (see WIPO Overview 3.1, section 3.2.1). Panels have held that the use of a domain name for illegitimate or illegal activity, here, claimed impersonation of an employee of the Complainant, and the Complainant has submitted evidence that this was done in an attempt to obtain orders of goods for shipment and constitutes bad faith (see WIPO Overview 3.1, section 3.4). As noted above, evidence submitted by the Complainant shows that an email address associated with the disputed domain name [...]@admfarms.com was used by the Respondent to send emails about purchasing golf carts purported to be an order from a legitimate employee of the Complainant. Evidence further shows the use of the ADM logo and legitimate address of the Complainant’s offices in the signature block of the said email to impersonate the Complainant. Previous panels have found similar activity as bad faith (see Archer-Daniels-Midland Company v. Musa Muhammed, WIPO Case No. D2026-0889). By registering the disputed domain name, which includes the Complainant’s mark and the term “farms”, especially considering that the Complainant is in agribusiness among other areas, and thereafter using it to engage in the manner described above is bad faith (see Archer-Daniels-Midland Company v. ADM, ADM, WIPO Case No. D2023-5357). Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitute 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 <admfarms.com> be transferred to the Complainant. /Raj Sachdev/ Raj Sachdev Sole Panelist Date: October 2, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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