ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION TikTok Ltd. v. M Abu bakar, oppo Case No. DME2025-0029 1. The Parties The Complainant is TikTok Ltd., United Kingdom, represented by Rouse Consultancy (Shanghai) Ltd., China. The Respondent is M Abu bakar, oppo, Pakistan. 2. The Domain Name and Registrar The disputed domain name is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 20, 2025. On October 20, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 20, 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, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 21, 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 22, 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 29, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 18, 2025. The Response was filed with the Center on October 29, 2025. The Respondent sent the email communications to the Center on October 30, 2025, October 31, 2025, and November 3, 2025.
page 2 The Complainant submitted a supplemental filing on October 30, 2025. The Center appointed Torsten Bettinger as the sole panelist in this matter on November 13, 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 the developer and operator of the social media application TikTok, launched in 2017. TikTok is a short-form video platform that allows users to create and share content directly from their smartphones and has rapidly become one of the world’s leading social media services. By 2018, TikTok was among the most downloaded mobile applications globally, having achieved hundreds of millions of downloads worldwide. As of 2025, TikTok has grown to a user base of approximately 1.94 billion registered users worldwide, with more than 1 billion monthly active users, placing it among the top social media platforms globally. TikTok has a significant presence in Montenegro, where it is used by an estimated 213,000 users, corresponding to around 42.7% of the country’s population, including a number of local creators and influencers who use the platform to promote Montenegrin culture and tourism. The Complainant has demonstrated that it owns numerous trade mark registrations for TIKTOK / TIK TOK, including, inter alia, the following: - TIKTOK, International Registration No. 1572059, designating Montenegro, registered on August 20, 2020, for goods in Nice Classes 6, 11, 14, 16, 18, 20, 21, 24, 25, 26, and 28. - TIKTOK, International Registration No. 1572336, designating Montenegro, registered on August 20, 2020, for goods and services in Nice Classes 9, 35, 36, 38, 41, 42, and 45. - TIKTOK, International Registration No. 1571879, designating Montenegro, registered on August 20, 2020, for goods and services in Nice Classes 3, 8, 10, 27, 29, 30, 31, 32, 33, 39, and 43. - TIKTOK, International Registration No. 1694683, designating Montenegro, registered on April 28, 2022, for goods and services in Nice Classes 2, 4, 5, 7, 12, 15, 34, 40, and 44. - TIK TOK, United States Trade Mark Registration No. 5653614, registered on January 15, 2019, for goods and services in Nice Classes 9, 38, 41, and 42. The Complainant is also the registrant of the domain name , which was registered on July 21, 1996, and has since been used as the Complainant’s official website in connection with its TikTok business. The disputed domain name was registered on September 9, 2024, and resolves to a website that prominently displays the Complainant’s TIKTOK word and logo trademarks, and purports to offer an APK download of an application called “TikTok18+”, which incorporates the Complainant’s TIKTOK mark and TikTok application name and provides short video services similar to those offered through the Complainant’s TikTok application.
page 3 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. With regard to the requirement of “identity or confusing similarity between the trademark and the domain name” pursuant to paragraph 4(a)(i) of the Policy, the Complainant submits that: - that it owns numerous trade mark registrations for TIKTOK and the TIKTOK logo in various jurisdictions, all of which significantly predate the registration of the disputed domain name; - for the purpose of assessing confusing similarity under the Policy, the country code Top-Level Domain “.me” is a technical requirement of registration and should be disregarded; - “tiktok18plus” incorporates the TIKTOK mark in its entirety, together with the number “18” and the descriptive term “plus” and that it is well established in prior UDRP decisions that the mere addition of numbers or generic/descriptive terms such as “18” and “plus” does not avoid a finding of confusing similarity where the Complainant’s mark remains clearly recognizable within the disputed domain name; - the inclusion of its highly reputed and distinctive TIKTOK mark in its entirety is, by itself, sufficient to establish confusing similarity under the Policy. With regard to the Respondent having no rights or legitimate interests in the disputed domain name, the Complainant submitted that: - mere registration of a domain name does not of itself confer any rights or legitimate interests under the Policy; - the Respondent is neither sponsored by nor affiliated with the Complainant and has never been authorized or licensed to use the TIKTOK mark, including in a domain name; - there is no evidence that the Respondent has ever been commonly known by the disputed domain name, and the use of a privacy service in the WhoIs further supports that the Respondent is not commonly known; - the website at the disputed domain name prominently displays the Complainant’s TIKTOK word and logo marks and purports to offer an APK download of an application called “TikTok18+”, which incorporates the Complainant’s TIKTOK mark and provides short-video services akin to those of the Complainant’s own application, but with provocative, adult-oriented content; - such use is clearly intended to create a false impression of affiliation or authorization, to suggest that the “TikTok18+” app is a modified version of the Complainant’s official application, cannot constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use under the Policy. - the composition of the disputed domain name itself is inherently misleading, as it is liable to cause Internet users to assume that it designates an alternative or special version of the Complainant’s TikTok application and implies an affiliation with the Complainant. Finally, with regard to the disputed domain name having been registered and being used in bad faith, the Complainant argues that: - it has owned registered rights in the TIKTOK mark since at least 2018, well before the registration of the disputed domain name on September 9, 2024; - through extensive global use of the TIKTOK mark for mobile short-video and social media services, the mark has acquired widespread reputation and distinctiveness, and a simple Internet search for “tiktok” returns results exclusively connected with the Complainant; - the disputed domain name resolves to a website prominently displaying the Complainant’s TIKTOK word and logo marks and offering an APK download for an application named “TikTok18+”, which incorporates the TIKTOK mark and offers short-video services akin to the Complainant’s TikTok application, but with provocative and adult-oriented content;
page 4 - such use clearly demonstrates the Respondent’s actual knowledge of the Complainant and its TIKTOK mark and creates a false impression of affiliation, thereby disrupting the Complainant’s business and trading on its goodwill for commercial gain by attracting Internet users through a likelihood of confusion, consistent with paragraph 4(b)(iv) of the Policy and prior UDRP decisions; - given the reputation of the TIKTOK mark, the disputed domain name will inevitably attract users seeking the Complainant’s services and that association with adult content risks damaging the Complainant’s reputation, which is further indicative of bad faith registration and use. B. Respondent The Center formally notified the Respondent of the Complaint on October 29, 2025, and, in accordance with paragraph 5 of the Rules, set November 18, 2025, as the due date for the Response. The Response was filed with the Center on October 29, 2025. The record shows, also, that the Respondent sent email communications to the Center on October 30, 2025, October 31, 2025, and November 3, 2025. The Respondent contends that - The disputed domain name was registered for a blog and informational website, not to impersonate or mislead users of TikTok. - The intention behind registering the disputed domain name was to create a general adult or open discussion blog, independent of TikTok’s platform or services. - The term “TikTok” in the disputed domain name was used in a descriptive, generic, and noncommercial sense to discuss trends and general content related to social media culture for adult audiences (18+). - No official TikTok logo, brand elements, or copyrighted materials were ever used on the website. - The disputed domain name was not registered to sell, mislead, or profit from the TikTok brand. - The Respondent has never offered to sell the disputed domain name, nor has the Respondent used it to redirect users to competing or adult services associated with TikTok. - There was no intent to confuse visitors or to take unfair advantage of the Complainant’s reputation. - The blog was purely informational, not commercial. - The disputed domain name is used for a noncommercial or fair use purpose, without intent for commercial gain or misleading users. This clearly applies here, as the site was a simple information-based blog, not a business or advertisement platform. - The Respondent requests the Panel to dismiss the Complaint and allow the Respondent to retain the disputed domain name, as there has been no evidence of bad faith or trademark abuse on the Respondent’s part. - If the Panel believes that certain elements (such as the word “TikTok”) are sensitive, the Respondent is open to renaming or adjusting the website content to ensure compliance and avoid any future misunderstanding. - The Respondent has always respected TikTok as a global brand and has no intention to misuse or harm its reputation. The Respondent’s website’s purpose was educational and informational. - Therefore, the Respondent requests that this case be dismissed in the Respondent’s favor and that the Respondent retain ownership of the disputed domain name. 6. Discussion and Findings Paragraph 4(a) of the Policy states that the Complainant must prove each of the three following elements: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith.
page 5 A. Preliminary Issue – Complainant’s Supplemental Filing The Complainant submitted a supplemental filing on October 30, 2025, which included the Complainant’s rebuttals to the Respondent’s Response. Under paragraphs 10 and 12 of the Rules, the Panel has discretion to determine the admissibility of unsolicited supplemental filings. As reflected in section 4.6 of the WIPO Overview 3.0, unsolicited supplemental filings are generally discouraged, unless specifically requested by the panel. In the present case, the Panel exercises its discretion not to consider the Complainant’s unsolicited supplemental filing in rendering its decision. B. 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. In the present case, the disputed domain name consists of the Complainant’s TIKTOK mark in its entirety, followed by the additional element “18plus”. The Panel finds that the Complainant’s TIKTOK mark is clearly recognizable within the disputed domain name. Where a complainant’s mark is recognizable within the domain name, the mere addition of other terms – whether numerals such as “18” or a descriptive term such as “plus” – does not prevent a finding of confusing similarity. The nature of such additional term(s) may however bear on assessment of the second and third elements. WIPO Overview 3.0, section 1.8. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. C. 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 3.0, section 2.1. On the present record, the Panel finds that the Complainant has made out a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name and that this case has not been rebutted. First, there is no evidence that the Respondent has been commonly known by the disputed domain name within the meaning of paragraph 4(c)(ii) of the Policy. The Respondent has not claimed, nor does the record show, that it is identified in any way as “tiktok18plus” or “TikTok18+”. To the contrary, the underlying registrant details are masked by a privacy service, which panels have generally regarded as weighing against a finding that a respondent is commonly known by the disputed domain name. There is also no indication that the Complainant has authorized, licensed, or otherwise permitted the Respondent to use its TIKTOK mark or to register any domain name incorporating that mark.
page 6 Secondly, the Respondent’s use of the disputed domain name does not qualify as a bona fide offering of goods or services under paragraph 4(c)(i) of the Policy. The disputed domain name reproduces the Complainant’s TIKTOK mark in its entirety together with the element “18plus” and resolves to a website prominently displaying the Complainant’s TIKTOK word and logo marks while offering an APK download for an application described as “TikTok18+”, which provides short-video services akin to those of the Complainant’s TikTok application, but with adult-oriented content. On these facts, the Respondent is not merely commenting on or referring to the Complainant’s service from a distance; it is presenting what appears to be an alternative or modified version of the Complainant’s application under the TIKTOK name and logo. Such conduct goes beyond what panels have regarded as bona fide use and instead falls squarely within the kind of misleading use the Policy is designed to address. Nor does the Respondent’s invocation of “informational and blogging purposes” and “no commercial intent” suffice to establish legitimate noncommercial or fair use under paragraph 4(c)(iii). Even if the site did not display obvious advertising or direct monetization (a point that is not clearly established on the record), the dispositive question under the Policy is whether the Respondent is using the domain name “without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue”. Here, the disputed domain name itself suggests an age-restricted variant of the Complainant’s well-known service, and the associated website uses the Complainant’s TIKTOK mark and logo to promote an app branded “TikTok18+”. This is inherently misleading and, given the adult nature of the content, carries a clear risk of tarnishing the Complainant’s mark. Panels have repeatedly found that such impersonation or quasi-impersonation does not amount to legitimate noncommercial or fair use, regardless of whether the respondent claims an absence of commercial motive. The Panel has considered the Respondent’s assertion that it did not intend to impersonate the Complainant and that the use of “TikTok” was descriptive and consistent with fair use principles. However, in light of the overall presentation of the site, the use of the Complainant’s exact mark and logo, the branding of the app as “TikTok18+”, and the functional similarity of the services offered, the Panel is not persuaded. Any disclaimer or subjective intent advanced by the Respondent cannot cure the objective impression conveyed to Internet users, namely that the disputed domain name and associated site are operated by, or affiliated with, the Complainant. In these circumstances, the Panel finds that none of the examples in paragraph 4(c) of the Policy, nor any other circumstance on the record, supports a finding of rights or legitimate interests on the part of the Respondent. The Respondent has failed to rebut the Complainant’s prima facie case. Accordingly, the Panel concludes that the Respondent has no rights or legitimate interests in respect of the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy. D. 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. 1. Bad faith Registration By the time of registration of the disputed domain name on September 9, 2024, the Complainant’s TIKTOK mark had already been registered for several years and had acquired a very substantial global reputation. As the Complainant has shown, TIKTOK is a highly distinctive and widely known mark in the field of short-form mobile video and social media services, and an online search for “tiktok” returns results overwhelmingly referring to the Complainant and its platform. The disputed domain name incorporates the TIKTOK mark in its entirety, together with the term “18plus”.
page 7 In the Panel’s view, this combination is not coincidental. The addition “18plus” would ordinarily be understood by Internet users as referring to an age-restricted or adult version of the Complainant’s service (i.e., “TikTok 18+”). Coupled with the global fame and distinctiveness of the TIKTOK mark, this strongly supports the inference that the Respondent was well aware of the Complainant and its trademark at the time of registration and chose the disputed domain name precisely because of its association with the Complainant. Panels have consistently held that the deliberate registration of a domain name incorporating a well-known mark, particularly in a way that suggests a specific version or variant of the complainant’s service, constitutes targeting and supports a finding of bad faith registration (see WIPO Overview 3.0, sections 3.1.1 and 3.2.1). The Respondent’s assertion that the disputed domain name was registered merely for “informational and blogging purposes” does not provide a credible alternative explanation for the selection of the Complainant’s distinctive mark plus “18plus” as a domain name. In the absence of any plausible, independent rationale, and having regard to the subsequent use of the disputed domain name, the Panel concludes that the Respondent registered the disputed domain name with knowledge of the Complainant and with the intent to capitalize on the Complainant’s trademark reputation. The Panel therefore finds that the disputed domain name was registered in bad faith. 2. Bad faith use The record further shows that the disputed domain name resolves to a website which prominently displays the Complainant’s TIKTOK word and logo marks, and purports to offer an APK download for an application branded “TikTok18+”. According to the Complainant’s evidence, this application provides short-video services akin to those of the Complainant’s TikTok platform, while emphasizing provocative and adult-oriented content. On these facts, the Respondent’s use of the disputed domain name goes well beyond neutral “informational” or critical commentary. The domain name itself, together with the replicated TIKTOK branding and the naming of the app as “TikTok18+”, is liable to lead Internet users to believe that the website and application are operated, endorsed, or at least authorized by the Complainant as an age-restricted variant of its service. This is classic impersonation / false affiliation of the kind UDRP panels have repeatedly found to constitute bad faith use (see WIPO Overview 3.0, sections 2.5.1 and 3.4). Even if the Respondent claims “no commercial intent”, the use of the disputed domain name to attract Internet users on the basis of confusion with the Complainant’s mark, and to associate that mark with adult content, is inherently abusive. Such conduct risks tarnishing the Complainant’s reputation and falls squarely within the type of behavior described in paragraph 4(b)(iv) of the Policy – namely, using a domain name incorporating a complainant’s trademark to attract, for commercial gain or other benefit, Internet users to a website by creating a likelihood of confusion as to source, sponsorship, affiliation, or endorsement. The Respondent’s bare assertion of noncommercial, “blogging” purposes and fair use does not align with the actual presentation and branding of the site. Whatever the Respondent’s stated intentions, the objective appearance is that of a site and app presented as a variant of the Complainant’s service. Panels have held that such quasi-impersonation cannot constitute legitimate noncommercial or fair use and is, instead, indicative of bad faith use. Taking these circumstances together, the Panel finds that the disputed domain name is being used in bad faith. Combined with the Panel’s conclusion on bad faith registration, the requirement of paragraph 4(a)(iii) of the Policy is satisfied.
page 8 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. /Torsten Bettinger/ Torsten Bettinger Sole Panelist Date: November 26, 2025
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