Westmore · UDRP DecisionFbsale.solutions
The Panel ordered transfer of <fbsale.solutions> to Meta Platforms, Inc. It found the domain confusingly similar to the Complainant’s FB trademark because it incorporated FB in its entirety with the additional term “sale.” The Respondent lacked rights or legitimate interests because the domain was used for a website offering Facebook accounts, Facebook Business Manager accounts, and Facebook pages for sale without accurately and prominently disclosing the lack of affiliation with the Complainant. The same commercial use and likelihood of confusion supported a finding of registration and use in bad faith.
The timeline behind fbsale.solutions
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 fbsale.solutions — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain combining a trademark abbreviation with a commercial term can satisfy all three UDRP elements when the associated website directly trades in accounts and assets linked to the trademark owner’s platform. The lack of an accurate and prominent affiliation disclosure was important to both the legitimate-interests and bad-faith analyses.
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 Meta Platforms, Inc. v. AREERAT RAEPHET Case No. D2026-2264 1. The Parties The Complainant is Meta Platforms, Inc., United States of America (“United States”), represented by Perkins Coie, United States. The Respondent is AREERAT RAEPHET, Thailand. 2. The Domain Name and Registrar The disputed domain name <fbsale.solutions> 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 May 26, 2026. On May 27, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 27, 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 June 2, 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 June 3, 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 June 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 25, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 29, 2026. page 2 The Center appointed Manuel Wegrostek as the sole panelist in this matter on July 2, 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 a leading provider of online social-media and social-networking services, the Facebook platform, founded in 2004. Today, the Complainant’s Facebook platform has over three billion monthly active users and over two billion daily active users on average worldwide. The Facebook platform is also available as an application for mobile devices, which in recent years has consistently ranked amongst the top applications in the market. To that end, in 2024, the Complainant’s famous Facebook brand ranked 21st in Interbrand’s Best Global Brands report. The Complainant is the owner of numerous trademark registrations for FACEBOOK (the “FACEBOOK Trademark”), including: - United States Trademark Registration No. 3734637, registered on January 5, 2010; - European Union Trade Mark Registration No. 005585518, registered on May 25, 2011; and - Thailand Trademark Registration No. บ33214, registered on April 9, 2007. Further, the Complainant is the owner of numerous trademark registrations for FB (the “FB Trademark”), including: - United Kingdom Trademark Registration No. UK00003441474, registered on March 20, 2020; - European Union Trade Mark Registration No. 18146501, registered on November 7, 2020; and - Brazil Trademark Registration No. 918596068, registered on August 18, 2020. The Complainant is also the owner of several domain names including the FACEBOOK Trademark, such as <facebook.com>, registered on March 29, 1997. The disputed domain name was registered on April 6, 2024. The Complainant provided evidence that the disputed domain name resolved to an active website displaying the letter sequence “fb” and titled with “FB SALE SOLUTIONS”, where Facebook accounts, Facebook Business Manager accounts, and Facebook pages were offered for sale. 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. On the first element of the Policy, the Complainant claims that the disputed domain name is confusingly similar to the FB Trademark. The disputed domain name wholly incorporates the FB Trademark, which is followed by the term “sale”. The addition of the term “sale” is not sufficient to dispel the ensuing confusing similarity between the FB Trademark and the disputed domain name. page 3 On the second element of the Policy, the Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name. There is no evidence to suggest that the Respondent is commonly known by the disputed domain name or has any rights in the disputed domain name. To the best of the Complainant’s knowledge, the Respondent has neither acquired nor applied for a trademark registration for “fb sale” or any variation thereof, as reflected in the disputed domain name. The Respondent is not a licensee of the Complainant, nor is affiliated with the Complainant in any way. The Complainant also has not authorized the Respondent to make any use of the FACEBOOK Trademark or FB Trademark. The Respondent has configured the disputed domain name to resolve to content that specifically targets the Complainant by purportedly selling Facebook accounts, whilst making prominent use of the FACEBOOK Trademark and FB Trademark. On the third element of the Policy, the Complainant asserts that the Respondent has registered and used the disputed domain name in bad faith. The Respondent knew of the Complainant’s rights to the FB Trademark and FACEBOOK Trademark when it registered the disputed domain name. The term “fb” has long been a well-known abbreviation for the Complainant’s famous FACEBOOK Trademark. The disputed domain name resolved to a fully operational e-commerce storefront dedicated to the unauthorized sale of the Complainant’s accounts and related services. The Respondent offers a broad catalogue of Facebook accounts, Facebook Business Managers, and Facebook Fan Pages at commercial price points. In choosing a domain name that so closely resembles the FB trademark to promote an unauthorized, derivative, competing service, the Respondent is taking advantage of a complainant’s mark for commercial gain. Further, the services sold on the Respondent’s website, in particular accounts designed to bypass identity verification and accounts with artificially inflated advertising spend limits, directly undermine the integrity, security, and trustworthiness of the Complainant’s platform. Moreover, in March 2026, the Complainant’s agents sent to the Respondent notifications demanding that the Respondent cease all unauthorized use of its FACEBOOK Trademark and FB Trademark and transfer the disputed domain name to the Complainant but didn’t receive any response. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules requires that the Panel’s decision be made “on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. The Complainant must evidence each of the three elements required by paragraph 4(a) of the Policy in order to succeed on the Complaint with respect to each disputed domain name, namely that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (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. 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. page 4 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. Further, the applicable Top-Level Domain in a domain name (e.g., “.com”, “.club”, “.nyc”) is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. This also applies to the Top- Level Domain “.solutions” of the disputed domain name. The disputed domain name contains the FB Trademark in its entirety, with the only difference being the addition of the term “sale”. The Panel finds the mark is recognizable within the disputed domain name. WIPO Overview 3.1, section 1.7. The addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise), in this case the term “sale”, does not prevent a finding of confusing similarity under the first element. WIPO Overview 3.1, section 1.8. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. 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. The Complainant has not authorized, licensed, or permitted the Respondent to register or use the disputed domain name, the FB Trademark or FACEBOOK Trademark. The Panel finds that there are no indications that the Respondent is commonly known by the disputed domain name or otherwise has any rights to or legitimate interests in the disputed domain name. Further, the disputed domain name is not used for a bona fide offering of goods or services. Rather, the Complainant provided evidence that the disputed domain name resolved to an active website displaying the letter sequence “fb”, where Facebook accounts, Facebook Business Manager accounts, and Facebook pages were offered for sale. The website linked to the disputed domain name did not accurately and prominently disclose the relationship, or rather the lack thereof, between the Respondent and the Complainant, thus creating the false impression that the Respondent might be authorized by or affiliated with the Complainant. 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. page 5 Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a well-known trademark, and particularly in the case of coined or fanciful marks, can by itself create a presumption of bad faith. Panels have moreover found the following types of evidence to support a finding that a respondent has registered a domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s mark: (i) actual confusion, (ii) seeking to cause confusion (including by technical means beyond the domain name itself) for the respondent’s commercial benefit, even if unsuccessful, (iii) the lack of a respondent’s own rights to or legitimate interests in a domain name, (iv) redirecting the domain name to a different respondent-owned website, even where such website contains a disclaimer, (v) redirecting the domain name to or mimicking the complainant’s (or a competitor’s) website, and (vi) absence of any conceivable good faith use. WIPO Overview 3.1, section 3.1.4. In the present case the, the disputed domain name incorporates the FB Trademark in its entirety, with the only difference being the addition of the term “sale”. Considering the distinctiveness and public presence of the FB Trademark, Internet users may think the disputed domain name is connected to the Complainant and would resolve to a website related to the Complainant. Further, the disputed domain name resolved to an active website displaying the letter sequence “fb”, where Facebook accounts, Facebook Business Manager accounts and Facebook pages were offered for sale. Moreover, the website linked to the disputed domain name did not accurately and prominently disclose the relationship, or rather the lack thereof, between the Respondent and the Complainant. As shown above, the Respondent lacks rights or legitimate interests in the disputed domain name. Therefore, the evidence leads to the conclusion that the Respondent has registered and used the disputed domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the FB Trademark and the FACEBOOK 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 <fbsale.solutions> be transferred to the Complainant. /Manuel Wegrostek/ Manuel Wegrostek Sole Panelist Date: June 16, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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