Westmore · UDRP decision
WIPO · Case No. D2026-0053

Www-gbwhatsapp.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <www-gbwhatsapp.com> to WhatsApp LLC. It found the domain confusingly similar because it reproduced the WHATSAPP mark in its entirety, with the additional terms “www” and “gb” not preventing confusing similarity. The Complainant established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests. Bad faith was established because the domain was registered more than a decade after the Complainant’s trademark registration and resolved to a page purporting to offer a modified version of the Complainant’s application while displaying the WHATSAPP mark and a modified figurative mark. The Panel held that the website disclaimer could not cure the bad faith shown by the overall circumstances and elements suggesting affiliation.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-03
Panelist(s)
Boghossian, Nayiri
Complainant
WhatsApp LLC
Respondent
Amanda Li
Counsel
Hogan Lovells (Paris) LLP
Disputed domain(s)
www-gbwhatsapp.com
Domain history UDRP Intelligence

The timeline behind www-gbwhatsapp.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 www-gbwhatsapp.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 www-gbwhatsapp.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a domain combining a trademark with software-related modifiers can satisfy all three UDRP elements when the associated website distributes or promotes a modified version of the trademark owner’s application and uses branding that suggests affiliation. It also shows that a disclaimer may carry little weight where the domain and overall website presentation otherwise point toward the trademark owner.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-03
Panel
Boghossian, Nayiri
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION WhatsApp LLC v. Amanda Li Case No. D2026-0053 1. The Parties The Complainant is WhatsApp LLC, United States of America (“United States”), represented by Hogan Lovells (Paris) LLP, France. The Respondent is Amanda Li, Singapore. 2. The Domain Name and Registrar The disputed domain name <www-gbwhatsapp.com> is registered with Name.com, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 7, 2026. On January 8, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 8, 2026, 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 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 January 19, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 8, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 20, 2026. The Center appointed Nayiri Boghossian as the sole panelist in this matter on February 26, 2026. 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 is a world-famous mobile messaging application provider founded in 2009. The Complainant owns many trademark registrations for WHATSAPP such as United States registration No. 3939463, registered on April 5, 2011, and International registration No. 1085539, registered on April 5, 2011. The disputed domain name was registered on October 10, 2022, and resolves to a website that purports to offer for download an unauthorized modified APK version of the Complainant’s WhatsApp. 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 a trademark in which the Complainant has rights. The Complainant has numerous registrations for the trademark WHATSAPP. The disputed domain name incorporates the Complainant’s trademark in its entirety. The addition of the prefix “www” and the letters “gb” does not prevent a finding of confusing similarity. The generic Top-Level Domain (“gTLD”) “.com” may be disregarded for the purposes of assessing confusing similarity. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is not a licensee of the Complainant. The Complainant did not authorize the Respondent to use its trademark. The disputed domain name is not used in connection with a bona fide offering of goods or services as the Respondent is using the domain name to offer for download an unauthorized modified APK version of the Complainant’s WhatsApp application. The Complainant submits that the Respondent cannot be viewed as a bona fide service provider, as it does not provide sales or repairs in relation to a product provided by the Complainant. Rather, the Respondent is using the Domain Name to purport to offer for download an unauthorized modified APK version of the Complainant’s WhatsApp application using the Complainant’s WHATSAPP trademark. Nevertheless, even if one is to apply the Oki Data criteria, the Respondent fails to fulfil the first and third Oki Data criteria, specifically: (a) The Respondent’s website purports to offer for download a third-party unauthorized modified version of the Complainant’s WhatsApp application; (b) The disclaimer-like statement is placed at the bottom of the page and fails to accurately and prominently disclose the Respondent’s lack of relationship with the Complainant. Moreover, by making numerous references to the Complainant’s WhatsApp platform, as well as featuring a modified version of the Complainant’s logos and figurative trademarks, the Respondent’s website suggests that the Respondent is affiliated with the Complainant. The additional functionality provided by the APK version of the WhatsApp application places the privacy and security of WhatsApp users at risk. The Respondent is not commonly known by the disputed domain name. The Respondent is not making a legitimate noncommercial or fair use of the disputed domain name as the website is likely used for commercial gain. The Complainant contends that the disputed domain name was registered and is being used in bad faith. The Respondent must have been aware of the Complainant’s trademark given its worldwide reputation and its inherent distinctiveness. Actual knowledge is demonstrated through the nature of the Respondent’s website as it makes prominent references to the Complainant, its trademark and official application, and features a modified version of the Complainant’s WhatsApp logos and figurative trademarks, as well as a green-themed colour scheme similar to that of the Complainant. The Respondent is attempting to create the misleading impression of association with the Complainant. The Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion as to the page 3 source, sponsorship, affiliation or endorsement of the Respondent’s website in bad faith. Furthermore, the software being promoted violates the WhatsApp Terms of Service and places the security of WhatsApp users at risk. The disclaimer-like statement does not accurately describe the Respondent’s non-affiliation with the Complainant and is not prominently visible, being located at the bottom of the homepage. 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 Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, 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 3.1, section 1.7. Although the addition of other terms here, “www” and “gb” 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 3.1, 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 that 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 3.1, 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 such as those enumerated in the Policy or otherwise. The Panel finds the second element of the Policy has been established. page 4 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 trademark as the disputed domain name was registered more than a decade after the registration of the Complainant’s trademark and it directs to a page, which purports to offer for download a modified version of the Complainant’s application and displays the Complainant’s trademark and a modified version of its figurative trademark. The Panel notes the disclaimer but is of the view that it cannot cure the bad faith evidenced by the overall circumstances, including the various elements that suggest affiliation, which are set out above. 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 3.1, section 3.2.1. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. 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 <www-gbwhatsapp.com> be transferred to the Complainant. /Nayiri Boghossian/ Nayiri Boghossian Sole Panelist Date: March 3, 2026

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

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