Westmore · UDRP decision
WIPO · Case No. D2026-3768

Piedmon-airlines.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <piedmon-airlines.com> to American Airlines, Inc. The domain omitted the final letter “t” from the PIEDMONT mark and added a hyphen and the term “airlines.” The Panel found confusing similarity, no rights or legitimate interests, and bad-faith registration and use. Although the domain did not resolve to an active website, its composition, passive holding, and configured MX servers supported the bad-faith finding, including a present and ongoing risk of phishing or fraudulent use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-30
Panelist(s)
Louis-Bernard Buchman
Complainant
American Airlines, Inc.
Respondent
Mohamad Nekui
Disputed domain(s)
piedmon-airlines.com
Citation weightrelies on 6 authorities
Domain history UDRP Intelligence

The timeline behind piedmon-airlines.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 piedmon-airlines.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 piedmon-airlines.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how a one-letter omission combined with an industry-specific term can preserve confusing similarity and strengthen the inference that a domain targets a trademark owner or affiliate. It also shows that an inactive website does not foreclose a bad-faith finding where the domain closely imitates an official domain and has configured MX servers capable of supporting deceptive email use.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used 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
2026-09-30
Panel
Louis-Bernard Buchman
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION American Airlines, Inc. v. Mohamad Nekui Case No. D2026-3768 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 Mohamad Nekui, Canada. 2. The Domain Name and Registrar The disputed domain name <piedmon-airlines.com> is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 24, 2026. On August 25, 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 26, 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 30, 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 September 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 22, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 23, 2026. page 2 The Center appointed Louis-Bernard Buchman as the sole panelist in this matter on September 25, 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, American Airlines, Inc., headquartered in Fort Worth, Texas, United States, is one of the world’s largest air carriers, serving, together with its affiliate companies, over 350 destinations in over fifty countries, with nearly 7,000 daily flights. Piedmont Airlines, Inc. (“Piedmont”), headquartered in Salisbury, Maryland, United States, traces its roots back to 1931, and is a wholly-owned subsidiary of the Complainant, as well as a regional carrier serving more than 50 destinations throughout the eastern United States, with nearly 400 daily flights. Piedmont has more than 11,000 employees that provide regional flight service to American Airlines travelers. The Complainant is the owner of several PIEDMONT trademarks, including the United States trademark No. 1619084 and the United States trademark No. 1619085, both registered by the Complainant’s predecessor in interest on October 23, 1990 (together hereinafter referred to as: “the Mark”). The Mark is used in commerce in the United States since 1948. Piedmont maintains a strong online presence through its primary domain name, <piedmont-airlines.com>, in continuous use since 1997. The disputed domain name <piedmon-airlines.com> was registered on December 29, 2025. At the time of the Complaint’s filing, the disputed domain name was not resolving to any active page. The Complainant has submitted evidence that Mail Exchange (“MX”) servers were configured under the disputed domain name. At the time of this Decision, the disputed domain name still does not resolve to any 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: (i) the disputed domain name reproduces the Mark, in which the Complainant has rights, and is confusingly similar to the Mark insofar as the disputed domain name is almost identical to the Mark; (ii) it never authorized the Respondent to use the Mark in any manner and it never had any affiliation with the Respondent, who has no rights or legitimate interests in respect of the disputed domain name; (iii) the Respondent has registered and is using the disputed domain name in bad faith; in particular, the Respondent had knowledge of the Mark when registering the disputed domain name, and creating a likelihood confusion with the Mark, the Respondent is using the disputed domain name in bad faith. The Complainant requests that the disputed domain name be transferred to the Complainant. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1. Procedural Aspects - Failure to Respond Under the Rules, paragraphs 5(f) and 14(a), the effect of a failure to submit a formal response by the Respondent is that, in the absence of exceptional circumstances, the Panel shall proceed to a decision on the basis of the Complaint. Under paragraph 4(a) of the Policy, it is the Complainant’s burden to establish that all three of the required criteria for a transfer of the disputed domain name have been met, even in the absence of a formal response. Under paragraph 14(b) of the Rules, the Panel is empowered to draw such inferences from the Respondent’s failure to file a formal response as it considers appropriate under the circumstances. In this case, the Panel finds that the Respondent has failed to rebut any of the reasonable factual assertions that are made and supported by evidence submitted by the Complainant. In particular, by failing to respond, the Respondent has failed to offer the Panel any of the types of evidence set forth in paragraph 4(c) of the Policy or otherwise, from which the Panel might conclude that the Respondent has any rights or legitimate interests in the disputed domain name, such as making legitimate noncommercial or fair use of the disputed domain name. Moreover, as discussed below, the Respondent has failed to provide any exculpatory information or reasoning that might have led the Panel to question the Complainant’s arguments that the Respondent has acted in bad faith. 6.2. Three Elements under Paragraph 4(a) of the Policy 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 notes that, as aforesaid, the Respondent did not rebut these assertions and finds that the disputed domain name is confusingly similar to the Mark, the differences in the disputed domain name being the missing final letter “t” and the addition of a hyphen and the term “airlines”. The Panel finds that 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. page 4 While the addition in the disputed domain name of another term, such as “airlines”, may bear on the 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. Regarding the generic Top-Level-Domain (“gTLD”) “.com” in the disputed domain name, it is well established that a gTLD does not generally affect the assessment for the purpose of determining identity or confusing similarity. WIPO Overview 3.1, section 1.11.1. 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 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. Furthermore, the Panel considers that the composition of the disputed domain name, particularly the addition of the term “airlines” as in Piedmont’s corporate name and in its official domain name, carries a risk of Internet confusion. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith 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 (including a blank or “coming soon” page) 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 composition of the disputed domain name, particularly the addition of the term “airlines” as in Piedmont’s corporate name and in its official domain name. The Panel finds that the Respondent was more likely than not aware of the Mark when it registered the disputed domain name. page 5 Regarding the implausibility of any good faith use, the Panel notes that the Complainant’s and Piedmont’s activity takes place in the air travel services industry, and that the Respondent used the disputed domain name to configure MX servers, thus creating for the Complainant and Piedmont a present and ongoing risk of phishing or fraudulent use. The Panel finds that in the circumstances of this case, the current passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Finally, some UDRP panels have held that in certain circumstances, registrants of domain names would have a duty to abstain from registering and using a domain name, which is either identical or confusingly similar to a prior trademark held by others and which would infringe upon or otherwise violate the rights of a third party. See Policy, paragraph 4(b); Nike, Inc. v. B. B. de Boer, WIPO Case No. D2000-1397; Nuplex Industries Limited v. Nuplex, WIPO Case No. D2007-0078; Mobile Communication Service Inc. v. WebReg, RN, WIPO Case No. D2005-1304; BOUYGUES v. Chengzhang, Lu Ciagao, WIPO Case No. D2007-1325; Media General Communications, Inc. v. Rarenames, WebReg, WIPO Case No. D2006-0964; and mVisible Technologies, Inc. v. Navigation Catalyst Systems, Inc., WIPO Case No. D2007-1141. The Panel finds that the Respondent has clearly not abided by such duty. 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 <piedmon-airlines.com> be transferred to the Complainant. /Louis-Bernard Buchman/ Louis-Bernard Buchman Sole Panelist Date: September 30, 2026

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

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