ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION WhatsApp LLC v. Muhammad Taimoor Case No. D2025-4211 1. The Parties The Complainant is WhatsApp LLC, United States of America (“United States”), represented by Hogan Lovells (Paris) LLP, France. The Respondent is Muhammad Taimoor, Pakistan. 2. The Domain Name and Registrar The disputed domain name is registered with Hosting Concepts B.V. d/b/a Registrar.eu. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 14, 2025. On October 14, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 15, 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 (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 15, 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 amended Complaint on October 16, 2025. 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 October 24, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 13, 2025. The Respondent sent an email communication to the Center on October 16, 2025.
page 2 The Center appointed Erica Aoki as the sole panelist in this matter on November 19, 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 a well-known global communications company and the operator of the WhatsApp messaging platform, which serves more than two billion users in over 180 countries. Since its founding in 2009 and acquisition by Meta Platforms, Inc. in 2014, the Complainant has continuously expanded its services and maintains substantial goodwill and global recognition under the WHATSAPP trademark. Since its launch, WhatsApp has become one of the fastest growing and most popular mobile applications in the world, with well over 2.8 billion monthly active users worldwide as of January 2024 The Complainant owns numerous trademark registrations for WHATSAPP worldwide, including: - United States Trademark Registration No. 3939463, WHATSAPP, registered on April 5, 2011; - International Trademark Registration No. 1085539, WHATSAPP, registered on May 24, 2011; - European Union Trademark Registration No. 009986514, WHATSAPP, registered on October 25, 2011; and - Pakistan Trademark Registration No. 302143, WHATSAPP, registered on May 27, 2011. All of these registrations predate the creation of the disputed domain name and protect the Complainant’s rights over its globally famous WHATSAPP trademark. Reflecting its global reach, the Complainant owns numerous domain names incorporating the WHATSAPP trademark across multiple generic Top-Level Domains (“gTLDs”) and country-code Top-Level Domains (“ccTLDs”). The Complainant also operates its official domain name , registered in 2008, which serves as its primary global platform for service access, account management, and user information. The Complainant has also made substantial investments to maintain a strong online presence through its official and highly followed social media channels. The Complainant’s official: - Facebook page has over 45 million followers, - X/Twitter account has 5.6 million followers, - and the Complainant also maintains active official channels on YouTube and LinkedIn. The disputed domain name was registered on September 5, 2024. The disputed domain name resolved to a Portuguese-language website offering unauthorized and modified versions of the Complainant’s software, including “GB WhatsApp” and “FM WhatsApp,” both of which are widely known as unofficial and potentially unsafe APK modifications of the official WhatsApp application. On September 4, 2025, the Complainant sent a cease-and-desist letter to the Respondent and submitted a Registrar contact form notice. No response was received. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied all three elements required under the Policy for the transfer of the disputed domain name. First, the Complainant asserts that the disputed domain name is confusingly similar to its well-known WHATSAPP trademark. The disputed domain name incorporates a misspelled version of the Complainant’s trademark (“Whatasapp” instead of “Whatsapp”), preceded by the letters “GB”. The Complainant submits
page 3 that such minor alterations constitute a classic case of typosquatting and do not prevent a finding of confusing similarity. According to the Complainant, the WHATSAPP trademark remains clearly recognizable within the disputed domain name, and the added prefix “GB” does not avoid confusion, particularly as the term “GB WHATSAPP” is commonly associated with unauthorized modified versions of the Complainant’s application. Second, the Complainant submits that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent has no affiliation with the Complainant and has never been authorized or licensed to use the WHATSAPP trademark or to distribute any modified or derivative version of the Complainant’s software. The Complainant states that the website to which the disputed domain name resolves promotes unauthorized and potentially unsafe APK versions of WhatsApp, including “GB WhatsApp” and “FM WhatsApp”. The site contains extensive promotional language encouraging users to download these modified applications, such as: GB WhatsApp is a feature-rich communication app designed for users who want more control, customization, and advanced tools than standard WhatsApp offers. FM WhatsApp APK v10.10 is one of the most advanced modified versions of WhatsApp currently available offering powerful customization and privacy features not found in the official version with theme control, large file sending, hidden chats, and ban protection. Statements acknowledging that the modified apps violate WhatsApp’s official policies, may lead to user account bans, are not available on official stores, and require users to download APKs from “trusted sources”. According to the Complainant, these admissions confirm that the Respondent knowingly offers unauthorized, infringing, and unsafe software, which can never constitute a bona fide offering of goods or services. The Complainant further submits that the Respondent’s website imitates the Complainant’s WhatsApp’s branding and trade dress, adopting a green-and-white color scheme nearly identical to the Complainant’s, as well as icons, logos, and a favicon that closely resembles the Complainant’s registered figurative trademarks. The site also features step-by-step guides explaining how to download and install the unauthorized APKs, a comparison table highlighting the “advantages” of modified versions over the official WhatsApp application, and commercial advertising banners and pop-up advertisements. The Complainant argues that such use demonstrates that the Respondent is exploiting the Complainant’s reputation to attract Internet traffic and monetize user visits through ads. The website also includes a small disclaimer-like statement in the “FM WhatsApp” FAQ section, stating: “Does FM WhatsApp have official support? No, it is not officially supported by WhatsApp Inc.” According to the Complainant, such a notice located at the bottom of one page does not mitigate the misleading overall impression created by the Respondent’s use of WhatsApp-like branding, logos, terminology, and presentation. The Complainant emphasizes that it has never authorized the Respondent to use its WHATSAPP trademark or visual identity in any manner and that the Respondent is clearly attempting to divert users seeking genuine WhatsApp services toward unauthorized and potentially harmful software. This conduct cannot confer rights or legitimate interests. Third, the Complainant argues that the disputed domain name was registered and is being used in bad faith. The Respondent intentionally registered a domain name incorporating a deliberate misspelling of the Complainant’s world-famous mark and used it to operate a website designed to mislead users into believing that the site is associated with, endorsed by, or related to the Complainant. The Complainant submits that
page 4 the Respondent’s imitation of its logos, colors, and branding combined with the promotion of infringing software, and the presence of commercial advertising demonstrates an intentional attempt to attract Internet users for commercial gain through confusion with the Complainant’s trademark. The Complainant further notes that the Respondent ignored its cease-and-desist letter, reinforcing the inference of bad faith. Accordingly, the Complainant submits that the Respondent’s conduct falls squarely within paragraph 4(b)(iv) of the Policy and requests that the disputed domain name be transferred. B. Respondent The Respondent sent an email to the Center on October 16, 2025, acknowledging receipt of the case and indicating that it will respond within the given time. However no further communication was received from the Respondent. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant must prove: (i) the disputed domain name is identical or confusingly similar to a mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in the disputed domain name; (iii) the disputed domain name was registered and is being used in bad faith. A. Identical or Confusingly Similar It is well established that the first element under the Policy functions primarily as a standing requirement (WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7). Under paragraph 4(a)(i) of the Policy, the Complainant must demonstrate that it has rights in a trademark and that the disputed domain name is identical or confusingly similar to that trademark. The Complainant owns numerous registered trademarks for WHATSAPP in multiple jurisdictions worldwide. In accordance with WIPO Overview 3.0, section 1.2.1, a valid trademark registration is sufficient to establish rights for the purpose of standing under the UDRP. The Complainant therefore satisfies the first part of the inquiry. The remaining question is whether the disputed domain name is identical or confusingly similar to the Complainant’s WHATSAPP trademark. The disputed domain name incorporates a misspelled version of the WHATSAPP mark “Whatasapp” with the addition of the letters “GB” at the beginning. The WHATSAPP trademark remains clearly recognizable within the disputed domain name. As affirmed in WIPO Overview 3.0, section 1.7, when a domain name incorporates a complainant’s trademark in its entirety, or contains a dominant recognizable feature of the mark, the domain name will generally be considered confusingly similar for purposes of the first UDRP element. Minor typographical alterations such as adding or omitting letters fall squarely within the doctrine of typosquatting, which panels have repeatedly held to be evidence of confusing similarity. WIPO Overview 3.0, section 1.9. The addition of the term “GB” likewise does not prevent a finding of confusing similarity. According to WIPO Overview 3.0, section 1.8, the addition of other terms whether descriptive, meaningless, or otherwise does not negate confusing similarity when the trademark remains recognizable within the domain name. The gTLD “.com” is disregarded for purposes of this assessment. For all these reasons, the disputed domain name is confusingly similar to the Complainant’s WHATSAPP trademark under paragraph 4(a)(i) of the Policy.
page 5 B. Rights or Legitimate Interests Under paragraph 4(c) of the Policy, a respondent may demonstrate rights or legitimate interests in a domain name by showing, for example, a bona fide offering of goods or services, being commonly known by the domain name, or making a legitimate noncommercial or fair use of it. The Complainant submits that the Respondent has no rights or legitimate interests in the disputed domain name. As explained in WIPO Overview 3.0, section 2.1, while the overall burden of proof rests with the complainant, panels recognize that proving a negative such as the absence of rights or legitimate interests, may require information primarily within the respondent’s knowledge. Therefore, once a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production shifts to the respondent to demonstrate otherwise. In the absence of such evidence, the complainant is deemed to have satisfied the second UDRP element. According to the Complainant, the Respondent cannot invoke any of the circumstances under paragraph 4(c) of the Policy. The Respondent is not a licensee of the Complainant, has no affiliation with the Complainant, and has never been authorized to use the WHATSAPP trademark in any manner. The Respondent is using the disputed domain name to offer unauthorized, modified APK versions of the Complainant’s WhatsApp application. Panels have recognized that the use of the Complainant’s WhatsApp’s modified logos and trade dress increases the risk of false affiliation and does not support a claim of rights or legitimate interests. There is also no evidence that the Respondent is commonly known by the disputed domain name. There is likewise no record of any trademark rights held by the Respondent in the term reflected in the domain name. Nor is the Respondent making legitimate noncommercial or fair use of the disputed domain name. The Respondent’s website not only promotes unauthorized modified APK versions of WhatsApp using imitative branding but also displays commercial advertising banners and pop-up ads. Taking all of the above into account, the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interest in the disputed domain name, and the Respondent has provided no evidence to rebut that case. Accordingly, the Complainant has satisfied paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith To satisfy the third element under paragraph 4(a)(iii) of the Policy, the Complainant must demonstrate that the disputed domain name was both registered and used in bad faith. Paragraph 4(b) of the Policy sets out illustrative circumstances of bad faith, including intentional attempts to attract Internet users for commercial gain by creating a likelihood of confusion with the complainant’s mark. While paragraph 4(b) lists four non-exhaustive examples of bad faith, the Complainant submits that paragraph 4(b)(iv) is particularly relevant in this case, and that additional factors outside that list also support a finding of bad faith. The Complainant’s WHATSAPP trademark is inherently distinctive and globally well known in connection with its messaging application. It has been continuously and extensively used since 2009 and has acquired considerable reputation and goodwill worldwide. Numerous UDRP panels have recognized the strength and renown of the WHATSAPP mark. The Complainant also notes that basic Internet searches for “WhatsApp” return results overwhelmingly referring to the Complainant and its official services. In light of this global renown, and the Complainant’s trademark registrations across multiple jurisdictions, the Respondent cannot credibly claim to have been unaware of the WHATSAPP trademark when registering the disputed domain name in September 2024.
page 6 The nature and content of the Respondent’s website further confirm that the Respondent had actual knowledge of the Complainant and deliberately targeted its mark. The website makes prominent references to WhatsApp, uses the WHATSAPP name throughout, and features both the Complainant’s figurative telephone logo and modified versions of it, in combination with a green-themed colour scheme similar to the Complainant’s branding. This leaves no doubt that the Respondent had the Complainant in mind when registering the disputed domain name and chose it precisely to capitalize on the WHATSAPP trademark. The Respondent’s failure to respond to the Complainant’s cease-and-desist letter and Registrar contact notice is an additional indicator of bad faith under WIPO Overview 3.0, section 3.6. Panels have held that a failure to respond to a well-founded cease-and-desist letter may support an inference of bad faith registration and use. Taken together, these circumstances show that the Respondent registered the disputed domain name with full knowledge of the Complainant’s rights and with the intention of targeting its WHATSAPP messaging service. The Complainant also submits that the disputed domain name is being used in bad faith. As discussed above, the disputed domain name is confusingly similar to the WHATSAPP trademark. The associated website reinforces this confusion by prominently referencing the Complainant and its WHATSAPP mark, adopting similar colors, icons and layout, and featuring the Complainant’s figurative telephone logo and a look-alike favicon. The Respondent’s website promotes unauthorized modified APK versions of the Complainant’s application, including “GB WhatsApp” and “FM WhatsApp”. The site describes these as “feature-rich” versions designed for users who “want more control, customization, and advanced tools than standard WhatsApp offers”, and claims that FM WhatsApp is “one of the most advanced modified versions” available, with “theme control, large file sending, hidden chats, and ban protection”. At the same time, the website admits that these versions are not available in official stores, may lead to bans for violating the Complainant’s policies, and “violate the official WhatsApp terms of use of the Complainant”. It further acknowledges that users’ data may be unprotected and that there is no official support. Despite these admissions, the website provides step-by-step guides for downloading the APKs, includes feature comparison tables highlighting the “advantages” of the modified versions over the official app, and displays commercial advertising banners and pop-up advertisements. The Complainant infers that the Respondent derives commercial gain from this traffic, whether through advertising revenue, reputational benefit, or other forms of advantage. Panels have recognized that such commercial or reputational benefit falls within the scope of paragraph 4(b)(iv) of the Policy. The use of a confusingly similar domain name to redirect Internet users to a website offering unauthorized modified versions of the Complainant’s app in direct competition with the official service, while imitating the Complainant’s branding and displaying advertisements, is consistent with an intentional attempt to attract users for commercial gain by creating a likelihood of confusion as to source, sponsorship, affiliation or endorsement. The Complainant further notes that the presence of a small “disclaimer-like” statement in the FAQ of the “FM WhatsApp” page, acknowledging that the app is not officially supported by WhatsApp Inc., does not cure the bad faith. The disclaimer is neither prominent nor sufficient to dispel the overall misleading impression created by the disputed domain name and website content. As reflected in WIPO Overview 3.0, section 3.7, even a clearly visible disclaimer will not normally prevent a finding of bad faith where all other circumstances point to targeting and confusion. In light of these circumstances, the Panel is satisfied that the disputed domain name was registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of the Policy, particularly under paragraph 4(b)(iv).
page 7 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. /Erica Aoki/ Erica Aoki Sole Panelist Date: December 2, 2025
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