ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION WhatsApp, LLC v. lin Feng Case No. D2025-3797 1. The Parties The Complainant is WhatsApp, LLC, United States of America (“United States” or “U.S.”), represented by Perkins Coie, LLP, United States. The Respondent is lin Feng, China. 2. The Domain Name and Registrar The disputed domain name is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 18, 2025. On September 18, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 18, 2025, 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 / Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 19, 2025, 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 amendment to the Complaint on September 22, 2025. The Center verified that the Complaint together with the amendment to the 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 26, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 16, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 27, 2025.
page 2 The Center appointed Andrea Cappai as the sole panelist in this matter on November 5, 2025. 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 is WhatsApp LLC, a United States limited liability company based in Menlo Park, California. It operates the WhatsApp messaging and voice-over-IP service, launched in 2009, which allows users to exchange text and voice messages, make voice and video calls, and share images, documents, locations and other content. The Complainant maintains an online presence through its principal domain name , registered in 2008, as well as a portfolio of additional domain names incorporating the WHATSAPP mark in various Top-Level Domains. The Complainant’s service is widely used and available in multiple languages, and the Complainant is active on major social media platforms. The Complainant owns numerous trademark registrations for WHATSAPP in multiple jurisdictions. By way of example, inter alia: - WHATSAPP – United States Trademark Registration No. 3939463, registered on April 5, 2011; - WHATSAPP – European Union Trademark No. 009986514, registered on October 25, 2011; and - WHATSAPP – Chinese Registration No. 21470708A, registered on December 21, 2017. The disputed domain name was registered on February 27, 2025. According to the Complaint the disputed domain name resolves to a website offering a tool described as “WhatsApp Group Blaster” and presenting itself as a bulk-messaging solution designed to operate on the WhatsApp platform. The website incorporates multiple elements associated with the Complainant, including use of the WHATSAPP name, a logo similar to the Complainant’s design mark, and colour schemes reminiscent of the WhatsApp interface. The Respondent is an individual located in China. Other than this information, no further details about the Respondent are available. 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 its longstanding and widely protected WHATSAPP trademark, used for many years and registered in multiple jurisdictions. It states that the Respondent has never been authorised to use its mark and that there is no evidence the Respondent is commonly known by the disputed domain name. The Complainant explains that the disputed domain name resolves to a website promoting a bulk-messaging tool branded “WhatsApp Group Blaster”, displaying the Complainant’s marks closely resembling its own, thereby creating a false impression of affiliation. The Complainant maintains that such use cannot constitute a bona fide offering of goods or services or legitimate noncommercial use, and notes that its Terms of Use expressly prohibit registrations and activities of this kind. With respect to bad faith, the Complainant contends that the Respondent must have been aware of its well-known trademark and that the composition of the disputed domain name indicates deliberate targeting It refers to the use of the disputed domain name for an unauthorised service presented with branding
page 3 evocative of the Complainant, the absence of any disclaimer, indications of a broader pattern of bad-faith conduct, and reports that the disputed domain name has been flagged as malicious. The Complainant also notes the Respondent’s failure to reply to cease-and-desist correspondence. The Complainant contends that, taken together, these factors support a finding of registration and use of the disputed domain name by the Respondent in bad faith under the Policy. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms, such as “group” and “blaster” may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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 recognised 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 3.0, 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.
page 4 The record shows that the disputed domain name resolves to a fraudulent website promoting a bulk-messaging tool falsely presented as operating through the Complainant’s service. The website makes prominent and unauthorised use of the Complainant’s trademarks and reproduces key elements of its visual identity. The inclusion of the terms “group” and “blaster” is plainly calculated to target the Complainant’s platforms, services, and user base, and to suggest an affiliation that does not exist. This type of impersonation seeks to create an impression of association with the Complainant and cannot amount to a bona fide offering of goods or services, nor to legitimate noncommercial or fair use within the meaning of the Policy. In the present case, the Respondent does not offer the Complainant’s genuine services at all; instead, it operates a website deliberately designed to suggest an affiliation with the Complainant. No disclaimer is provided to dispel that false impression, and the absence of any clear disclosure further undermines any claim to rights or legitimate interests. 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 notes that the Respondent registered the disputed domain name with clear knowledge of the Complainant’s inherently distinctive and widely recognised WHATSAPP trademark. The term “WhatsApp” has no meaning other than as a direct reference to the Complainant, and even minimal searching would have revealed the Complainant’s exclusive rights. Reproducing the mark in its entirety together with the terms “group” and “blaster” demonstrates an intent to target the Complainant and its users. Panels have long held that the registration of a domain name identical or confusingly similar to a well-known mark by an unaffiliated party creates a presumption of bad faith (WIPO Overview 3.0, section 3.1.4). That presumption is reinforced here by the Respondent’s use: the disputed domain name resolves to a fraudulent website imitating the Complainant’s visual identity, displaying its trademarks, and promoting an unauthorised bulk-messaging tool falsely presented as operating on the Complainant’s platform. The Panel concludes that the Respondent’s use of the disputed domain name, with no disclaimer, creates a false impression of source, affiliation, sponsorship, or endorsement with the Complainant. This conduct falls squarely within paragraph 4(b)(iv) of the Policy, as the Respondent has sought to attract users for commercial gain by creating a likelihood of confusion with the Complainant. The fact that the disputed domain name has been flagged by cybersecurity vendors as potentially malicious further heightens the risk to users and aligns with prior findings of bad faith. The Panel notes that the Respondent’s failure to answer cease-and-desist correspondence, coupled with its use of a privacy service, provides additional support for an inference of bad faith. The record also suggests a broader pattern of abusive registrations, confirming that the disputed domain name was registered and used with full awareness of the Complainant’s rights and with an intent to exploit them. 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 3.0, section 3.2.1. The Panel finds that the Complainant has established the third element of the Policy.
page 5 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 be transferred to the Complainant. /Andrea Cappai/ Andrea Cappai Sole Panelist Date: Novembre 19, 2025
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