Westmore · UDRP DecisionGruposwhatsapp.blog
The Panel ordered transfer of <gruposwhatsapp.blog>. It found the domain confusingly similar to the WHATSAPP mark because it reproduced the mark in full and the added term “grupos” did not avoid confusing similarity. The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests, and the domain was used for a website displaying explicit adult content, promoting gambling services, and using the Complainant’s trademark. The Panel concluded that the Respondent intentionally attempted to attract Internet users for commercial gain by creating confusion with the WHATSAPP mark.
The timeline behind gruposwhatsapp.blog
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 gruposwhatsapp.blog — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain that combines a well-known mark with a service-related term can satisfy all three UDRP elements when it is used for unrelated explicit and gambling content designed to draw traffic through trademark confusion. The website’s prominent use of the mark and apparent commercial purpose were particularly important beyond the domain’s textual similarity alone.
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. ivana guedes Case No. D2026-2069 1. The Parties The Complainant is WhatsApp, LLC, United States of America, represented by Perkins Coie LLP, United States of America. The Respondent is ivana guedes, Brazil. 2. The Domain Name and Registrar The disputed domain name <gruposwhatsapp.blog> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 13, 2026. On May 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 18, 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 (REDACTED FOR PRIVACY Privacy Protect, LLC (PrivacyProtect.org)) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 18, 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 amendment to the Complaint on May 20, 2026. The Center verified that the Complaint together with the amendment to 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 May 22, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 12, 2026. page 2 The Center appointed Andrea Jaeger-Lenz as the sole panelist in this matter on June 16, 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 operates a messaging and voice-over-IP service and mobile application under the brand WHATSAPP. The WhatsApp service of the Complainant is used by over two billion people in more than 180 countries, is available in 60 different languages and enables its users to communicate individually or in groups by sending text and voice messages, make voice and video calls, and share images, documents and other content with one another, see Annexes 4 and 5 to the Complaint. The Complainant owns numerous trademark registrations around the world in the term WHATSAPP, including the following (as per Annex 8 to the Complaint): • United States of America trademark no. 3,939,463 WHATSAPP (word), registered on April 5, 2011, for services in Class 42; • European Union trademark no. 009986514 WHATSAPP (word), registered on October 25, 2011, for goods and services in Classes 9, 38 and 42; • International trademark no. 1396913 WHATSAPP (word), registered on December 21, 2017, for goods and services in Classes 9, 35, 38, 42 and 45. The Complainant operates its official website under the domain name <whatsapp.com> and, in addition, owns numerous other domain names consisting of or containing the WHATSAPP trademark, as per Annex 6 to the Complaint. The disputed domain name was registered on August 6, 2025. At the filing of the present Complaint, the disputed domain name resolved to a website offering adult-oriented content and images, promoting third- party gambling services and making use of the Complainant’s trademark, as per Annex 10 to the Complaint. 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 identical or confusingly similar to a trademark, in which the Complainant owns rights. The Complainant refers to numerous trademarks registrations around the world it holds in the term WHATSAPP and points to the fact that the disputed domain name wholly incorporates this trademark. The Complainant argues that the prefix “grupos” means “groups” in Spanish and Portuguese, therefore is non-distinctive and accordingly does not prevent a finding of confusing similarity, while the applicable Top-Level Domain “.blog” may be disregarded for the purposes of the assessment of this element. On the second element, the Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. According to the Complainant, the Respondent is not commonly known by the disputed domain name nor has any rights in the disputed domain name independent of the Complainant’s well established trademark rights. The Complainant argues that, to the best of its knowledge and pursuant to a search in WIPO’s Global Brand Database provided as Annex 9 to the Complaint the Respondent has neither applied for or obtained a trademark registration for “Grupos Whats App” or any variation thereof. The page 3 Complainant adds that the Respondent is neither a licensee of or affiliated with the Complainant, and had not been authorized by the Complainant to make any use of its trademark either. Moreover, the Complainant claims, the Respondent cannot refer to any legitimate interests in respect of the disputed domain name, because prior UDRP panels have found that it cannot constitute fair use where a respondent effectively impersonates or suggests sponsorship or endorsement by the trademark owner. And this, so the Complainant contends, is what the Respondent has been doing by creating the disputed domain name in the way it is configured and by causing it to resolve to a website with adult-oriented content and promotion of third-party gambling services while making prominent use of the Complainant’s trademark. On the third element, the Complainant contends that the disputed domain name was registered and is being used in bad faith. According to the Complainant, its trademark is inherently distinctive and well-known throughout the world due to continuous and extensive use, for which the Complainant points to Annex 8 to the Complaint. All results obtained by typing the term “WhatsApp” into the Google search engine refer to the Complainant, as per Annex 15 to the Complaint. Thus, the Complainant states, it is inconceivable that the Respondent was not aware of the Complainant’s trademark upon registration of the disputed domain name. Further, by choosing a domain name that so closely resembles the Complainant’s trademark, and by using it to promote adult-oriented content and online gambling services, the Respondent is taking advantage of the Complainant’s trademark for commercial gain. In particular, the Respondent’s use of the disputed domain name to host explicit adult content and offer gambling services is, according to the Complainant, in itself evidence of bad faith. 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, “grupos”, 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 page 4 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. Here, the Respondent’s use of the disputed domain name incorporating the Complainant’s well-known trademark to resolve to a website displaying explicit adult content, promoting gambling services, and making use of the Complainant’s trademark does not amount to a bona fide offering of goods or services, nor a legitimate noncommercial or fair use. 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 has created the disputed domain name wholly incorporating the Complainant’s WHATSAPP trademark in combination with the term “grupos” which is related to the area of the Complainant’s activities and has used the disputed domain name to resolve to a website displaying explicit adult content, promoting gambling services, and making use of the Complainant’s trademark. 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, in particular Annex 10 to the Complaint, the Panel finds that by the registration and use of the disputed domain name, the Respondent has clearly intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s trademark. 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 <gruposwhatsapp.blog> be transferred to the Complainant. /Andrea Jaeger-Lenz/ Andrea Jaeger-Lenz Sole Panelist Date: June 30, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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