Westmore · UDRP decision
WIPO · Case No. D2025-4373

1001instalike.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <1001instalike.com> after finding all three UDRP elements established. The domain incorporated the Complainant’s INSTA mark with the additional terms “1001” and “like” and resolved to an Indonesian-language website offering Instagram followers, likes, and views. The Panel found no authorization, bona fide offering, legitimate noncommercial or fair use, or evidence that the Respondent was commonly known by the domain. Bad faith was established from the Respondent’s targeting of Instagram, including explicit Instagram references, a similar gradient color scheme, commercial services connected to the platform, and failure to respond to a cease-and-desist letter.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-12-08
Panelist(s)
Svorčík, Martin
Complainant
Instagram, LLC
Respondent
1001 Insta Like
Disputed domain(s)
1001instalike.com
Citation weightrelies on 3 authorities
Domain history UDRP Intelligence

The timeline behind 1001instalike.com

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 1001instalike.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of 1001instalike.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain that combines a platform-associated mark with terms describing social-media engagement can satisfy all three UDRP elements when the corresponding website sells services tied directly to that platform. The website’s explicit Instagram references and similar visual presentation supplied evidence extending beyond the domain string itself and supported a finding of deliberate commercial targeting.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registered and used in bad faithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-12-08
Panel
Svorčík, Martin
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Instagram, LLC v. 1001 Insta Like Case No. D2025-4373 1. The Parties The Complainant is Instagram, LLC, United States of America (“United States”), represented by Hogan Lovells (Paris) LLP, France. The Respondent is 1001 Insta Like, Indonesia. 2. The Domain Name and Registrar The disputed domain name <1001instalike.com> is registered with CV. Jogjacamp (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 24, 2025. On October 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 30, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center sent an email communication to the Complainant on October 30, 2025, confirming the registrant and contact information disclosed by the Registrar. The Center verified that 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 November 6, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 26, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 27, 2025. The Center appointed Martin Švorčík as the sole panelist in this matter on December 3, 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. page 2 4. Factual Background The Complainant, Instagram, LLC, is a United States company founded in 2010 (hereinafter also as “Instagram”). It operates the well-known online social networking service Instagram, frequently abbreviated as “Insta”, which enables users to create, share, and edit photos and videos. The Instagram platform was launched in 2010 and has since achieved substantial global recognition and goodwill. In 2012, the Complainant was acquired by Meta Platforms, Inc. (formerly Facebook, Inc.). The Complainant owns many trade marks for INSTA in many jurisdictions around the world, such as: - United States Trademark No. 5061916, INSTA, registered on October 18, 2016; - Indonesian Trademark No. IDM000594774, INSTA, registered on October 24, 2025; and - European Union Trade Mark No. 014810535, INSTA, registered on May 23, 2018. The Complainant is also the holder of numerous domain names consisting of or including the term“Insta”, including but not limited to <instagram.com> as well as, <instagram.fr> <instagram.co>, <instagram.ae> and<instagram.com.vn>. The disputed domain name was registered on May 5, 2017. The disputed domain name resolves to a website in Indonesian titled “1001 INSTALIKE” that purports to offer for sale Instagram followers, likes and views and features a pink/purple gradient colour scheme that is very similar to Complainant's pink/purple gradient colour scheme. 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 the trademark INSTA; when comparing the disputed domain name <1001instalike.com> with the Complainant’s trademark, it becomes evident that the domain name incorporates the word INSTA in its entirety, rendering the domain name at stake confusingly similar to the Complainant’s trademark. The inclusion of the term “1001” and “like” does not alleviate confusion. Therefore, the disputed domain name <1001instalike.com> misleadingly implies a connection with the Complainant. - the Respondent has no rights or legitimate interests in the disputed domain name, because the Respondent incorporates the Complainant’s trademark in the disputed domain name without any license or authorization from the Complainant. Additionally, the Respondent has not conducted a legitimate business under the disputed domain name, there is hence no legitimate or non-commercial use of the disputed domain name. The use of the disputed domain name to purport to offer a service for purchasing Instagram followers, likes and views involves the Respondent engaging in fraudulent conduct. The Respondent is unable to demonstrate a right or legitimate interest in the Domain Name. - Given the reputation of the Complainant’s well-known INSTA trademark and the use to which the disputed domain name has been put, the Respondent cannot credibly argue that he registered the disputed domain name without knowledge of the Complainant’s rights. The disputed domain name resolves to website which purport to offer a service for purchasing Instagram followers, likes and views; the Respondent is using the disputed domain name to exploit the goodwill and reputation attached to the Complainant's trade marks for commercial gain by attracting Internet users to its website and offering them illegitimate services that damage the functionality and intended operation of the Instagram platform, as well as by creating a false page 3 impression of association with the Complainant. This conduct amounts to registration and use of the Domain Names in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy directs that the Complainant must establish each of the following: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. 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 here, “1001” and “like” 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 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. 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 page 4 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. From the evidence available on record, it is also clear that the Respondent is not sponsored by or associated with the Complainant in any manner. Moreover, the Complainant has not granted the Respondent any permission, license, or authorization to use the Complainant’s trademarks in any capacity, including within domain names. The Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services as contemplated under paragraph 4(c)(i) of the Policy, nor is the Respondent making a legitimate noncommercial or fair use of the domain name without intent for commercial gain to misleadingly divert consumers or to tarnish the Complainant’s trademarks under paragraph 4(c)(iii) of the Policy. Furthermore, the Respondent does not appear to be commonly known by the disputed domain name and there is no evidence that might support such finding. 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 must have been aware of the Complainant’s rights when registering the domain, as the sole purpose of the disputed domain name was to gain financial profit from the success of the Complainant and his reputation. In fact, it was the Respondents intention as it may be inferred from the content of the website to which the disputed domain name resolves, which makes explicit reference to Instagram and features a similar gradient color scheme to that used on the Complainant's Instagram platform. See Instagram, LLC v. Whois Privacy, Private by Design, LLC / Ayesh Karunaratne, WIPO Case No. D2021-2233 (<downloadgram.com>): The Panel takes note that the content of the website to which the disputed domain name resolves prominently refers to INSTAGRAM and offers a tool for use with that application. This evidence confirms that the Respondent is seeking to target the INSTAGRAM trademark through the disputed domain name and affirms the finding of confusing similarity. The Respondent failed to respond to the Complainant's lawyers' cease and desist letter which is further evidence of bad faith; See ACCOR, SoLuxury v. WhoisGuard Protected, WhoisGuard, Inc., Van Dung, WIPO Case No. D2018-1237 (<sofitelmplsdining.com>). Panels have held that the use of a domain name for illegitimate activity here, claimed impersonation, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. See Instagram, LLC v. Privacy Protect, LLC (PrivacyProtect.org) / Elnur Alizade, WIPO Case No. D2021-1845 (<insta-shark.com>): “Given the Respondent's lack of rights or legitimate interests in the disputed domain name, and the confusing similarity of the disputed domain name to the Complainant's INSTA trademark, any use of the disputed domain name by the Respondent almost certainly implies an affiliation with the Complainant that does not exist and so would be a use in bad faith. Furthermore, as the disputed domain name resolved to a website which, for a fee, purported to artificially increase the number of Instagram ‘followers’, ‘likes’, ‘views’, and ‘comments’, the Respondent has used the disputed domain name to attract, for commercial gain, page 5 Internet users to a website by creating confusion in the minds of the public as to an association between the website and the Complainant.” The Panel finds that the Complainant has established the third element of the Policy. 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 <1001instalike.com> be transferred to the Complainant. /Martin Švorčík/ Martin Švorčík Sole Panelist Date: December 8, 2025

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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