Westmore · UDRP DecisionAwsdns-105.net + 5 more domains
The Panel consolidated the six domain names against a single Respondent, found them confusingly similar to Complainant’s AWS mark, found no rights or legitimate interests, and found bad-faith registration and use based on Respondent’s actual knowledge and passive holding under the totality of the circumstances. All six domains were ordered transferred.
The timeline behind awsdns-105.net
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 awsdns-105.net — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The Panel found that Respondent had actual knowledge of the AWS mark when registering the domains because of the mark’s significant global reputation and the domains’ replication of Complainant’s Route 53 DNS-record format. Considering the mark’s nature and fame, the domains’ structure, their inactivity, and the absence of any explanation, the Panel also found passive holding amounted to bad-faith use.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
NATIONAL ARBITRATION FORUM DECISION Amazon Technologies, Inc. v. Adeo lawunmi / Justin Rose Claim Number: FA2607002233247 PARTIES Complainant is Amazon Technologies, Inc. ("Complainant"), represented by James F. Struthers of Richard Law Group, Inc., Texas, USA. Respondent is Adeo lawunmi / Justin Rose ("Respondent"), Multiple Locations. REGISTRAR AND DISPUTED DOMAIN NAMES The domain names at issue are <awsdns-105.net>, <awsdns-108.com>, <awsdns-118.com>, <awsdns-145.org>, <awsdns-315.net> and <awsdns-450.org> (collectively "Domain Names"), registered with Name.com, Inc. PANEL The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding. Nicholas J.T. Smith as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on July 17, 2026; Forum received payment on July 17, 2026. On July 20, 2026, Name.com, Inc. confirmed by e-mail to Forum that the <awsdns-105.net>, <awsdns-108.com>, <awsdns-118.com>, <awsdns-145.org>, <awsdns-315.net> and <awsdns-450.org> domain names are registered with Name.com, Inc. and that Respondent is the current registrant of the names. Name.com, Inc. has verified that Respondent is bound by the Name.com, Inc. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy"). On July 23, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 12, 2026 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@awsdns-105.net, postmaster@awsdns-108.com, postmaster@awsdns-118.com, postmaster@awsdns-145.org, postmaster@awsdns-315.net, postmaster@awsdns-450.org. Also on July 23, 2026, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts. Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default. On August 14, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nicholas J.T. Smith as Panelist. Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent. RELIEF SOUGHT Complainant requests that the Domain Names be transferred from Respondent to Complainant. PRELIMINARY ISSUE: MULTIPLE RESPONDENTS In the instant proceedings, Complainant has alleged that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder." Complainant contends that the registrants for the Domain Names are related because: 1) the Domain Names are all similar variants of Complainant's AWS mark 2) the Domain Names were registered with the same Registrar and within a 3-day period of one another 3) the Domain Names are all inactive. In essence each of these domain names consists of the AWS mark, the abbreviation "dns" and a number and none of them resolve to active websites. This evidence, in the Panel's opinion, strongly suggests that the Domain Names are owned/controlled by a single Respondent; were the named Respondents unrelated, it would be unlikely that a multiple unconnected entities would register very similar domain names with the same registrar during a 3-day time period, with and then use none of them. In light of these contentions, which none of the identified Respondents deny, the Panel concludes that, on the balance of probabilities, the Domain Names are commonly owned/controlled by a single Respondent who is using multiple aliases. Hereafter the single Respondent will be referred to as "Respondent" in this Decision. PARTIES' CONTENTIONS A. Complainant Complainant, Amazon Technologies Inc., is one of the world's leading retailers and offers IT infrastructure services under the AWS mark. In particular, Complainant offers the Amazon Route 53 DNS Service which allows customers to route end users to their websites reliably with globally dispersed Domain Name System (DNS) servers and automatic scaling. This service automatically creates various DNS records that look like "ns-2048.awsdns-64.com". Complainant has rights in the AWS mark through Complainant's registration of the mark with the United States Patent and Trademark Office ("USPTO") (Reg. No. 5,676,725 registered on February 12, 2019). Each of the Domain Names are confusingly similar to Complainant's AWS mark because they each incorporate Complainant's mark in its entirety, simply adding the abbreviation "dns", a hyphen, a three-digit number and a generic top-level domain ("gTLD"). Respondent lacks rights and legitimate interests in the Domain Names. Respondent is not commonly known by the Domain Names and Complainant has not authorized or licensed Respondent any rights in the AWS mark. Additionally, Respondent does not use the Domain Names for any bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, the Domain Names are inactive. Respondent registered and uses the Domain Names in bad faith as Respondent fails to make an active use of the Domain Names and hopes to cause confusion through the use of the AWS mark in the Domain Names. Finally, Respondent registered the Domain Names with actual knowledge of Complainant's rights in the AWS mark given the reputation of the Complainant and the nature of the Domain Names, which replicate the format used by Complainant's Route 53 DNS Service. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant holds trademark rights for the AWS mark. Each of the Domain Names is confusingly similar to Complainant's AWS mark. Complainant has established that Respondent lacks rights or legitimate interests in the Domain Names and that Respondent registered and has used the Domain Names in bad faith. DISCUSSION Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable." Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith. In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.1 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint"). Identical and/or Confusingly Similar Complainant has rights in the AWS mark based upon registration of the mark with the USPTO (e.g. Reg. No. 5,676,725 registered on February 12, 2019). Registration of a mark with the USPTO sufficiently confers a complainant's rights in a mark for the purposes of Policy ¶ 4(a)(i). See Target Brands, Inc. v. jennifer beyer, FA 1738027 (Forum July 31, 2017) ("Complainant has rights in its TARGET service mark for purposes of Policy ¶ 4(a)(i) by virtue of its registration of the mark with a national trademark authority, the United States Patent and Trademark Office ("USPTO").). The Panel finds that each of the Domain Names is confusingly similar to the AWS mark as they each incorporate the entire AWS mark while adding a generic term, a three-digit number and a gTLD. Adding a generic term or terms (including a number) to a gTLD to a mark fails to sufficiently distinguish a disputed domain name from a mark per Policy ¶ 4(a)(i). See Skechers U.S.A., Inc. and Skechers U.S.A., Inc. II v. Svensson Viljae, FA 1784650 (Forum June 1, 2018) (finding confusing similarity where "[t]he disputed domain name <skechers-outlet.com> adds a hyphen and the generic term 'outlet' to Complainant's registered SKECHERS mark, and appends the '.com' top-level domain."); see also MTD Products Inc v J Randall Shank, FA 1783050 (Forum June 27, 2018) ("The disputed domain name is confusingly similar to Complainant's mark as it wholly incorporates the CUB CADET mark before appending the generic terms 'genuine' and 'parts' as well as the '.com' gTLD."). The Panel finds Complainant has satisfied Policy ¶ 4(a)(i). Rights or Legitimate Interests Complainant alleges that Respondent holds no rights or legitimate interests in the Domain Names. In order for Complainant to succeed under this element, it must first make a prima facie case that Respondent lacks rights and legitimate interests in the Domain Names under Policy ¶ 4(a)(ii), and then the burden shifts to Respondent to show it does have rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006) and AOL LLC v. Gerberg, FA 780200 (Forum Sept. 25, 2006) ("Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names."). The Panel holds that Complainant has made out a prima facie case. Complainant asserts that Respondent has no rights or legitimate interests in the Domain Names as Respondent is not commonly known by the Domain Names, nor has Complainant authorized Respondent to use the AWS mark. Respondent has no relationship, affiliation, connection, endorsement or association with Complainant. WHOIS information can help support a finding that a respondent is not commonly known by the disputed domain name, especially where a privacy service has been engaged. See State Farm Mutual Automobile Insurance Company v. Dale Anderson, FA 1613011 (Forum May 21, 2015) (concluding that because the WHOIS record lists "Dale Anderson" as the registrant of the disputed domain name, the respondent was not commonly known by the <statefarmforum.com> domain name pursuant to Policy ¶ 4(c)(ii)); see also Kohler Co. v. Privacy Service, FA 1621573 (Forum July 2, 2015) (holding that the respondent was not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii) where "Privacy Service" was listed as the registrant of the disputed domain name). The WHOIS information of record lists "Adeo lawunmi / Justin Rose" as the registrants of record. Coupled with Complainant's unrebutted assertions as to absence of any affiliation or authorization between the parties, the Panel finds that Respondent is not commonly known by the Domain Names in accordance with Policy ¶ 4(c)(ii). Each of the Domain Names is inactive and there is no other evidence of any intention to use the Domain Names for any purpose, be it a bona fide offering or legitimate non-commercial use. In the absence of any additional evidence (none available in the present case) inactive holding of a disputed domain name is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) or legitimate noncommercial or fair use under Policy ¶ 4(c)(iii). See CrossFirst Bankshares, Inc. v Yu-Hsien Huang, FA 1785415 (Forum June 6, 2018) ("Complainant demonstrates that Respondent fails to actively use the disputed domain name as it resolves to an inactive website. Therefore, the Panel finds that Respondent fails to actively use the disputed domain name for a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶ 4(c)(i) or (iii)."). The Panel finds Complainant has satisfied Policy ¶ 4(a)(ii). Registration and Use in Bad Faith The Panel finds on the balance of probabilities that, at the time of registration of the Domain Names, April 2026, Respondent had actual knowledge of Complainant's AWS mark. The Complainant had developed a significant global reputation in the AWS mark and there is no obvious explanation, nor has one been provided, for an entity to register six domain names that wholly incorporate the AWS mark (that replicate the DNS records created by the Complainant's Route 53 DNS Service), other than to take advantage of Complainant's reputation in the AWS mark. In the absence of rights or legitimate interests of its own this demonstrates registration in bad faith under Policy ¶ 4(a)(iii). The Panel notes that the actions of Respondent in this matter do not fall under the arguments set out in Policy ¶ 4(b). However, these arguments are merely illustrative rather than exclusive to support a finding of bad faith. See Bloomberg Finance L.P. v. Domain Admin - This Domain is For Sale on GoDaddy.com / Trnames Premium Name Services, FA 1714157 (Forum Mar. 8, 2017) (determining that Policy ¶ 4(b) provisions are mere illustrative of bad faith, and that the respondent's bad faith may be demonstrated by other allegations of bad faith under the totality of the circumstances). It is well accepted that the elements of Policy ¶ 4(b) are not exclusive and that a Panel may consider all of the circumstances of a given case, including passive holding, in making its bad faith analysis. See Telstra Corporation Limited v. Nuclear Marshmallows, Case No. D2000-0003 (WIPO Feb. 18, 2000) (after considering all the circumstances of a given case, it is possible that a "[r]espondent's passive holding amounts to bad faith."); see also Regions Bank v. Darla atkins, FA 1786409 (Forum June 20, 2018) ("Respondent registered and is using the domain name in bad faith under Policy ¶ 4(a)(iii) because Respondent uses the domain name to host an inactive website.") Respondent has, without alternative explanation (or active use), registered six domain names containing the AWS mark. Inactive holding of a domain name can be evidence of bad faith under Policy ¶ 4(a)(iii) and, after considering the totality of the circumstances (including the nature and fame of the AWS mark and the structure of the Domain Names) and in the absence of any Response or other explanation for such inactivity by the Respondent, the Panel finds that this inactive holding of the Domain Names amounts to use in bad faith per Policy ¶ 4(a)(iii). The Panel finds Complainant has satisfied Policy ¶ 4(a)(iii). DECISION Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED. Accordingly, it is Ordered that the <awsdns-105.net>, <awsdns-108.com>, <awsdns-118.com>, <awsdns-145.org>, <awsdns-315.net> and <awsdns-450.org> domain names be TRANSFERRED from Respondent to Complainant. Nicholas J.T. Smith, Panelist Dated: August 14, 2026 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page
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