Westmore · UDRP DecisionAres-managements.com
The Panel ordered transfer of <ares-managements.com> to Ares Management LLC. It found the domain confusingly similar to the Complainant’s ARES and ARES MANAGEMENT marks, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The prior website displayed the Complainant’s mark and globe design and was found consistent with impersonation and a false impression of affiliation. False and/or inaccurate registration information and the failure to respond to the Complainant’s notice further supported bad faith.
The timeline behind ares-managements.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 ares-managements.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a slight typographical variation of a trademark—here, a hyphen and an added “s”—does not avoid confusing similarity when the mark remains recognizable. It also shows the evidentiary importance of prior website content: although the domain was inactive by the decision date, its earlier display of the Complainant’s mark and design supported findings of impersonation, lack of legitimate interests, and bad faith. The Panel treated inaccurate registration information and failure to answer notice as corroborating rather than standalone factors.
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 Ares Management LLC v. gao shuan xiong Case No. D2026-3752 1. The Parties The Complainant is Ares Management LLC, United States of America (“United States”), represented by Greenberg Traurig, LLP, United States. The Respondent is gao shuan xiong, Taiwan Province of China. 2. The Domain Name and Registrar The disputed domain name <ares-managements.com> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 21, 2026. On August 24, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 25, 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 (Redacted for privacy) 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 amended Complaints on August 27, 2026 and August 28, 2026. The Center verified that the Complaint together with the amended Complaints 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 31, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 20, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 21, 2026. page 2 The Center appointed Estela Mariel de Luca 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. 4. Factual Background The Complainant, Ares Management LLC, is a subsidiary of Ares Management, L.P., a global alternative asset manager headquartered in Los Angeles, United States, active in the field of financial services, namely investment advisory and management services for credit, private equity, and real estate. The Complainant has over 60 offices, including in the United States, Europe, Asia, and Australia. The Complainant has been operating under the marks ARES and ARES MANAGEMENT since at least September 1997. The Complainant is the owner of the following trademarks: - China trademark registration No. 8537439 ARES, registered on September 21, 2011, in International class 36. - China trademark registration No. 71321872 ARES, registered on January 28, 2024, in International class 36. - China trademark registration No. 8537435 registered on September 7, 2013, in International class 36. - China trademark registration No. 8537436 ARES MANAGEMENT, registered on September 21, 2011, in international class 36. The Complainant owns the domain name <aresmgmt.com>, registered on March 19, 2002, and <aresmanagement.com>, registered on December 29, 2011. The Complainant’s investors regularly use the Ares Management website to access the Complainant’s services, and a large percentage of the Complainant’s business is generated through website traffic. The disputed domain name was registered on December 26, 2025. It originally resolved to a website displaying the Complainant’s trademark and images taken from the Complainant's website. At the time of filing of the Complaint, the disputed domain name resolved to a website displaying the Complainant’s ARES MANAGEMENT mark and globe design, while also referring to a third-party hedge fund. At the time of this Decision, the disputed domain name does not resolve to an active website. 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 famous ARES and ARES MANAGEMENT marks, and its numerous ARES domain names. In particular, it submits that the disputed domain name incorporates the ARES and ARES MANAGEMENT marks in their entirety, altering them only by adding a hyphen and the letter “s” at the end, followed by the generic Top-Level Domain (“gTLD”) “.com”. The Complainant further asserts that the disputed domain name is virtually identical to <aresmanagement.com>, which it has registered since 2011 and which redirects to the Ares Management website, the only difference being the additional letter “s ” and the hyphen. page 3 The Complainant submits that the Respondent has no rights or legitimate interests in respect of the disputed domain name because: (1) the Respondent has not been authorized, licensed, or otherwise permitted by the Complainant to register or use the disputed domain name; (2) the Respondent is not commonly known by the disputed domain name and, to the Complainant's knowledge, holds no trademark applications or registrations anywhere in the world for any mark incorporating the Complainant’s marks; (3) the Respondent has never operated any bona fide or legitimate business under the disputed domain name and is not making a legitimate noncommercial or fair use of it, but is instead using it to impersonate the Complainant and its website, displaying the Complainant’s ARES MANAGEMENT mark and globe design, references to a third party, and an email address, in order to induce visitors to provide personal information. According to the Complainant, such use is confusing for consumers and, at worst, aimed at obtaining their personal information; and (4) the Respondent is preventing the Complainant from registering or using the disputed domain name. The Complainant contends that the Respondent registered and is using the disputed domain name in bad faith. The disputed domain name was allegedly used to host a website passing itself off as the Complainant’s, displaying the ARES MANAGEMENT mark, the Ares globe design, and a New York, United States cityscape image similar to the one on the Complainant’s website. The Complainant further argues that the Respondent had actual knowledge of the Complainant’s ARES marks at the time of registration, and that registering a domain name incorporating the mark of a well-known company is sufficient to give rise to an inference of bad faith. The Complainant also alleges that the Respondent used false contact information in registering the disputed domain name, noting that the postal code provided to the Registrar is not valid for the city indicated, and that the same code was used by the Respondent in the registration of another domain name targeting the Complainant, which was the subject of a previous UDRP proceeding resulting in a finding of bad faith. The Complainant finally states that its counsel sent the Respondent letters on January 5 and 6, 2026, demanding transfer of the disputed domain name, and that the disputed domain name was subsequently suspended by the Registrar and currently has Client Hold status. 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 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. page 4 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 and the addition of the hyphen and the letter “s” does not prevent a finding of confusing similarity. WIPO Overview 3.1, sections 1.7 and 1.8. Accordingly, the disputed domain name is confusingly similar to the mark 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 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. There is no evidence that the Respondent has been commonly known by the disputed domain name, nor that the Respondent is affiliated with the Complainant or has been authorized or licensed to use the ARES and ARES MANAGEMENT trademarks or to register any domain name incorporating such marks. Furthermore, the record contains no indication that the Respondent has used the disputed domain name in connection with a bona fide offering of goods or services, or that it has made a legitimate noncommercial or fair use of the disputed domain name. The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy. The Panel notes that the disputed domain name resolved to a website displaying the Complainant’s ARES MANAGEMENT mark and globe design, which indicates that the Respondent likely intended to impersonate the Complainant. Such use cannot be considered a bona fide offering of goods or services or a legitimate noncommercial or fair use of the disputed domain name. Panels have held that the use of a domain name for illegitimate activity, including impersonation, can never confer rights or legitimate interests on a respondent. See WIPO Overview 3.1, section 2.13.1. page 5 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 finds that the Complainant's rights in the ARES and ARES MANAGEMENT marks predate the registration of the disputed domain name. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s ARES and ARES MANAGEMENT marks, as well as the composition of the disputed domain name. In light of these circumstances, the Panel finds that the Respondent was likely aware of the Complainant and its marks when registering the disputed domain name, which supports a finding of bad faith registration. The Panel further notes that, although the disputed domain name does not currently resolve to an active website, it previously resolved to a website displaying the Complainant's ARES MANAGEMENT mark and globe design, passing itself off as the Complainant's website. The Panel finds that such use is consistent with an intent to impersonate the Complainant and to create a false impression of affiliation with it, which constitutes bad faith use under paragraph 4(b)(iv) 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. WIPO Overview 3.1, section 3.2.1. Panels have held that the use of a domain name for illegitimate activity, here, claimed 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. In addition, the Panel notes that the Complainant gave notice to the Respondent to which it did not receive any response and the Respondent’s use of false and/or inaccurate contact information in the registration of the disputed domain name, which in the circumstances of this case constitutes an additional factor supporting a finding of bad faith. 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 <ares-managements.com> be transferred to the Complainant. /Estela Mariel de Luca/ Estela Mariel de Luca Sole Panelist Date: October 5, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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