Regions.org UDRP takes away generic domain from Domainer

Regions Bank, a U.S. financial institution with trademark rights in REGIONS since 1995, pursued the domain Regions.org after discovering it was used in phishing emails impersonating the bank.

The domain, registered in 2001 and held under privacy, displayed banking-related PPC links and a “for sale” notice, while also sending fake “security alert” messages to trick customers into revealing account credentials.

The Respondent, a domain investor based in Italy, did not answer the complaint, leaving unrebutted claims of bad faith. The panel found the name identical to the bank’s mark, with no legitimate use, and concluded it was registered and used to attract users for commercial gain through confusion.

Final decision: Grant the transfer of Regions.org to the Complainant.

Regions Bank v. Andrea Denise Dinoia / Puglia.com srls

Claim Number: FA2507002166096

PARTIES

Complainant is Regions Bank (“Complainant”), represented by Rachel Hofstatter of Honigman LLP, District of Columbia, USA. Respondent is Andrea Denise Dinoia / Puglia.com srls (“Respondent”), Italy.

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is regions.org, registered with Sav.com, LLC.

PANEL

The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.

Debrett G. Lyons as Panelist.

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on July 16, 2025; Forum received payment on July 16, 2025.

On July 17, 2025, Sav.com, LLC confirmed by e-mail to Forum that the regions.org domain name is registered with Sav.com, LLC and that Respondent is the current registrant of the name. Sav.com, LLC has verified that Respondent is bound by the Sav.com, LLC 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 22, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 11, 2025 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@regions.org. Also on July 22, 2025, 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 12, 2025, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, Forum appointed Debrett G. Lyons 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 name be transferred from Respondent to Complainant.

PARTIES’ CONTENTIONS

A. Complainant

Complainant asserts trademark rights in REGIONS which it uses in connection with its banking services. Complainant submits that the disputed domain name is confusingly similar to its trademark.

Complainant alleges that Respondent has no rights or legitimate interests in the disputed domain name. Further, Complainant alleges that Respondent registered and used the disputed domain name in bad faith.

In particular, Complainant asserts that Respondent has used the disputed domain name to impersonate Complainant and in an unlawful effort to induce Complainant’s customers to divulge their banking passwords.

B. Respondent

Respondent failed to submit a Response in this proceeding.

FINDINGS

The factual findings pertinent to the decision in this case are that:

1. Complainant provides banking services by reference to the trademark, REGIONS;

2. Complainant is the owner of, inter alia, United States Patent and Trademark Office (“USPTO”) Reg. No. 1,881,600, registered on February 28, 1995, for REGIONS;

3. the disputed domain name was registered on July 4, 2001, using a privacy service to shield the name of Respondent; and

4. the domain name has been used to send emails which pose as having originated from Complainant.

DISCUSSION

Paragraph 15(a) of the Rules instructs this Panel to “decide a complaint on the basis of the statements and documents submitted 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.

Identical and/or Confusingly Similar

Paragraph 4(a)(i) of the Policy requires a two-fold enquiry—a threshold investigation into whether a complainant has rights in a trademark, followed by an assessment of whether the disputed domain name is identical or confusingly similar to that trademark.

Paragraph 4(a)(i) does not distinguish between registered and unregistered trademark rights (see, for example, Microsoft Corporation v. Story Remix / Inofficial, FA 1734934 (Forum July 10, 2017). A trademark registered with a national authority is evidence of trademark rights (see, for example, Mothers Against Drunk Driving v. phix, FA 174052 (Forum Sept. 25, 2003)). Complainant provides evidence of its registration of REGIONS with the USPTO, a national trademark authority, and so the Panel finds proof of trademark rights.

The domain name then differs from the trademark by simple addition of the gTLD, “.org” to the trademark. For the purposes of comparison of the trademark and domain name, the gTLD can be disregarded (see, for example, Am. Int’l Group, Inc. v. Domain Admin. Ltd., FA 1106369 (Forum Dec. 31, 2007)). The Panel does not need to consider Complainant’s submissions regarding confusing similarity since in these circumstances the weight of UDRP opinion is that the compared terms are treated as identical (see, for example, Abt Elecs., Inc. v. Ricks, FA 904239 (Forum Mar. 27, 2007) (“The Panel also finds that Respondent’s abt.com domain name is identical to Complainant’s ABT mark since addition of a generic top-level domain (“gTLD”) is irrelevant when conducting a Policy ¶ 4(a)(i) analysis.”)).

The Panel therefore finds that the requirements of paragraph 4(a)(i) of the Policy are satisfied.

Rights or Legitimate Interests

Paragraph 4(c) of the Policy states that any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate rights or legitimate interests to a domain name for purposes of paragraph 4(a)(ii) of the Policy:

(i) before any notice to you of the dispute, your use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or

(ii) you (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or

(iii) you are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

Complainant need only make out a prima facie case that Respondent has no rights or legitimate interests in the disputed domain name, after which the onus shifts to Respondent to rebut that case by demonstrating those rights or interests (see, for example, Do The Hustle, LLC v. Tropic Web, D2000‑0624 (WIPO Aug. 21, 2000)).

There is no evidence that Respondent has any trademark rights of its own. The name of the domain name owner does not carry any suggestion that Respondent might be commonly known by the domain name. The domain name currently resolves to a parked domain with links to “Online Banking Accounts”, “Online Banking” and “Online Bank Checking” directing Complainant’s customers to websites of its competitors. The landing page carries a notice that the domain name “may be for sale”. Further, and more sinister, is evidence that the domain name has been used as part of the email address, alerts@alert.regions.org, which has been used to send so-called “Security Alert,” emails to banking customers stating that their bank account had been locked and providing instructions (via a bogus link) to unlock the account.

Such use is manifestly not a bona fide offering of goods or services or legitimate non-commercial or fair use under the Policy (see, for example, Am. Int’l Group, Inc. v. Busby, FA 156251 (Forum May 30, 2003) finding that the respondent attempts to pass itself off as the complainant online, which is blatant unauthorized use of the complainant’s mark and is evidence that the respondent has no rights or legitimate interests in the disputed domain name).

A prima facie case has been made and so the onus shifts to Respondent to rebut that case by demonstrating those rights or interests. Absent a Response, the onus is not met and so the Panel finds that Complainant has satisfied the second limb of the Policy.

Registration and Use in Bad Faith

Complainant must prove on the balance of probabilities both that the disputed domain name was registered in bad faith and used in bad faith.

Further guidance on that requirement is found in paragraph 4(b) of the Policy, which sets out four circumstances, any one of which is taken to be evidence of the registration and use of a domain name in bad faith if established.

The four specified circumstances are:

(i) circumstances indicating that the respondent has registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or

(ii) the respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or

(iii) the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

(iv) by using the domain name, respondent has intentionally attempted to attract, for commercial gain, internet users to respondent’s website or other on-line location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on the site or location.

The Panel finds that Respondent’s conduct falls squarely under paragraph 4(b)(iv). The Panel has found the domain name to be identical to the trademark. Confusion is inevitable. The use of the domain name is for commercial gain. In terms of the Policy, the Panel finds that Respondent has used the disputed domain name to attract, for commercial gain, internet users to an online location by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of that location (see, for example, Abbvie, Inc. v. James Bulow, FA 1701075 (Forum Nov. 30, 2016) (“Respondent uses the abbuie.com domain name to impersonate Complainant’s CEO. Such use is undeniably disruptive to Complainant’s business and demonstrates bad faith pursuant to … Policy ¶ 4(b)(iv)”)).

The Panel finds that Complainant has satisfied the third and final element of the Policy.

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 regions.org domain name be TRANSFERRED from Respondent to Complainant.

Debrett G Lyons, Panelist

Dated: August 13, 2025

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