Westmore · UDRP DecisionWhatsapp-assistant.com
The Panel ordered transfer of <whatsapp-assistant.com> after finding all three UDRP elements established. The domain reproduced the WHATSAPP mark with the term “assistant”; the Respondent did not rebut the Complainant’s prima facie showing on rights or legitimate interests; and the domain was used for a website promoting a “WhatsApp AI Assistant” in a manner that created a false impression of connection with the Complainant and intentionally attracted users for commercial gain through confusion.
The timeline behind whatsapp-assistant.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 whatsapp-assistant.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates a straightforward trademark-plus-term case in which the added word “assistant” did not avoid confusing similarity and instead aligned with the product promoted on the associated website. The combination of the complete WHATSAPP mark, trademark-branded website content, a false appearance of affiliation, and an unrebutted record supported transfer under paragraph 4(b)(iv).
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION WhatsApp LLC v عبدالرحم%u مصطفي Case No. D2026-0727 1. The Parties The Complainant is WhatsApp LLC, United States of America (“United States”), represented by Hogan Lovells (Paris) LLP, France. The Respondent is عبدالرحم %u مصطفي , Egypt. 2. The Domain Name and Registrar The disputed domain name <whatsapp-assistant.com> 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 February 20, 2026. On February 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 20, 2026, 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 February 23, 2026, 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 February 25, 2026. 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 February 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 20, 2026. page 2 The Center appointed Knud Wallberg as the sole panelist in this matter on March 25, 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. 4. Factual Background The Complainant is the provider of the WhatsApp application, a popular mobile messaging application allowing users to exchange messages via smartphones without having to pay for short message service (SMS) messages. The Complainant was founded in 2009, and its WhatsApp application now has over three billion active users worldwide. The Complainant has registered numerous trademarks consisting of the term “WhatsApp” in many jurisdictions throughout the world, including International Registration No. 1085539, WHATSAPP, registered on May 24, 2011, for goods and services in international classes 9 and 38; Indian Trademark Registration No. 2149059, WHATSAPP, registered on May 24, 2011, in classes 9 and 38; and Indian Trademark Registration No. 3111463 WHATSAPP, registered on November 30, 2015, in classes 9, 35, 36, 38, 42 and 45. The Complainant is also the owner of numerous domain names, consisting of the WHATSAPP trademark, under various generic Top-Level Domains (“gTLDs”) as well as under many country code Top-Level Domains (“ccTLDs”). The disputed domain name was registered on February 23, 2024. At the time of the filing of this Complaint the disputed domain name resolved to an active website that featured the Complaints trademark WHATSAPP and which promoted a product or service called “WhatsApp AI Assistant”. 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 trademarks in which it has rights as it comprises the Complainant’s WHATSAPP trademark, with the addition of the term “assistant” as suffix, under the gTLD “.com”. The Complainant further contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services. The Respondent is not a licensee of the Complainant. The Respondent is not affiliated with the Complainant in any way, nor has the Complainant authorized the Respondent to make any use of its WHATSAPP trademark, in a domain name or otherwise The Complainant finally contends that the disputed domain name was registered and is being used in bad faith. The Complainant submits that given the Complainant’s renown and goodwill worldwide, the Respondent had actual knowledge of the Complainant and its rights at the time of registration of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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, “assistant”, may bear on assessment of the second and third elements, the Panel finds the addition of such term 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. 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. 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. page 4 Given the circumstances of the case, including the evidence on record of the use of the Complainant’s trademark WHATSAPP, and the distinctive nature and reputation of this mark, it is inconceivable to the Panel in the current circumstances that the Respondent registered the disputed domain name without prior knowledge of the Complainant and the Complainant’s mark. The Panel therefore finds that the disputed domain name was registered in bad faith. The disputed domain name has been used to host a website, which clearly gave Internet users the impression that the website was a website of the Complainant or a website that was somehow connected to the Complainant, which was not the case. The Panel therefore finds that there can be no doubt that the disputed domain name has been used in bad faith to intentionally attempt “to attract, for commercial gain, Internet users to the Respondent’s website or other online location, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website”. Paragraph 4(b)(iv) of the Policy, and WIPO Overview 3.0, section 3.1.4. Noting the above; that the disputed domain name incorporates the Complainant’s distinctive trademark WHATSAPP; that the Respondent has not replied to the Complainant’s contentions; and considering all the facts and evidence of the case, the Panel finds that the requirements of paragraph 4(a)(iii) of the Policy are also fulfilled in this case. 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 <whatsapp-assistant.com> be transferred to the Complainant. /Knud Wallberg/ Knud Wallberg Sole Panelist Date: April 8, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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