Westmore · UDRP decision
WIPO · Case No. D2026-2290

Fmwhatsap.app, Gbwhata.app

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <fmwhatsap.app> and <gbwhata.app>. It found the domain names confusingly similar to the Complainant’s WHATSAPP mark, held that the Respondent’s websites promoting and assisting downloads of unauthorized purportedly modified WhatsApp applications did not confer rights or legitimate interests, and concluded that the Respondent registered and used the domain names in bad faith to attract users through confusion regarding source, sponsorship, affiliation, or endorsement. The Panel rejected the Respondent’s request for a finding of Reverse Domain Name Hijacking.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-07-06
Panelist(s)
Kalafatoğlu, Mehmet Polat
Complainant
WhatsApp LLC
Respondent
Zahoor Ahmad
Disputed domain(s)
fmwhatsap.app, gbwhata.app
Domain history UDRP Intelligence

The timeline behind fmwhatsap.app

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 fmwhatsap.app — 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
Outcome by domain

How each disputed name was decided in this proceeding.

fmwhatsap.appTransferred
gbwhata.appTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of fmwhatsap.app.
Reverse Domain Name Hijacking
RDNH requested by the respondent; not found.
Westmore Insight

The decision illustrates that characterizing a site as informational or review-oriented will not establish legitimate interests where the overall presentation uses a well-known mark and similar brand elements to promote and assist downloads of unauthorized modified software. It also shows that a disclaimer placed on a secondary page or tab may carry little weight when the broader website presentation suggests affiliation.

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
2026-07-06
Panel
Kalafatoğlu, Mehmet Polat
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION WhatsApp LLC v. Zahoor Ahmad Case No. D2026-2290 1. The Parties The Complainant is WhatsApp LLC, United States of America (“US”), represented by Perkins Coie LLP, US. The Respondent is Zahoor Ahmad, Pakistan, self-represented. 2. The Domain Names and Registrar The disputed domain names <fmwhatsap.app> (the “first disputed domain name”) and <gbwhata.app> (the “second disputed domain name”) are registered with Sav.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 28, 2026. On May 28, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On May 28, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (“REDACTED FOR PRIVACY”) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 29, 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 30, 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 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 22, 2026. The Response was filed with the Center on June 11, 2026. The Center also received an email from the Respondent on May 29, 2026. The Center appointed Mehmet Polat Kalafatoglu as the sole panelist in this matter on June 22, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is WhatsApp LLC, a US limited liability company. It operates the well-known WhatsApp messaging and voice-over-IP service and mobile application. WhatsApp has over two billion users in over 180 countries and is one of the most popular mobile applications globally. The Complainant is the owner of numerous trademark registrations for WHATSAPP in different jurisdictions, including the following: - the US trademark registration No. 3939463, registered on April 5, 2011; - the European Union trademark registration No. 009986514, registered on October 25, 2011; and - the International trademark registration No. 1396913, registered on December 21, 2017. In addition, the Complainant owns numerous device trademark registrations for its logo, which is green and white and features an image of a phone, including the International trademark registration No. 1109890, registered on January 10, 2012. The Complainant also notes that it owns and operates numerous domain names consisting of the WHATSAPP trademark, such as the domain name <whatsapp.com>, which is used for its official website. The first disputed domain name was registered on July 17, 2025. The second disputed domain name was registered on July 15, 2025. They both resolve to websites which prominently display the Complainant’s WHATSAPP trademark and logos that are confusingly similar to the Complainant’s device trademark. It appears that on these websites, the Respondent promotes purportedly modified and enhanced versions of the Complainant’s application and gives instructions to download such versions. 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 names. The Complainant’s contentions are summarized below. First, the Complainant claims that the disputed domain names are confusingly similar to its trademarks. Second, the Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain names. In this regard, the Complainant submits that there is no evidence to suggest that the Respondent is commonly known by the disputed domain names or has any rights in the disputed domain names independent of the Complainant’s well-established trademark rights. The Respondent is not a licensee of the Complainant and is not authorized to make any use of the WHATSAPP trademark. The Respondent specifically targets the Complainant by offering an unauthorized, purportedly modified version of the Complainant’s applications, whilst making prominent use of the Complainant’s trademarks. The Complainant also notes that the Respondent does not prominently disclose its lack of relationship with the Complainant despite repeatedly making prominent use of the WHATSAPP trademark. Third, the Complainant asserts that the disputed domain names were registered and are being used in bad faith. First, the Complainant notes that the Respondent knew of the Complainant’s trademark rights when registering the disputed domain names. Second, the disputed domain names and their corresponding website content are so obviously connected with the Complainant and its trademarks and services that such use suggests opportunistic bad faith. Third, by using the disputed domain names, the Respondent has page 3 intentionally attempted to attract Internet users to its website by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of the Respondent’s websites and putative services marketed therein. Lastly, the modified unauthorized applications promoted via the disputed domain names may be used to spread malware and for other illegal activities, and the disputed domain names have been flagged by several independent cybersecurity vendors as being malicious in connection with malware. B. Respondent The Respondent contends that the Complainant has not satisfied the elements required under the Policy for a transfer of the disputed domain names. The Respondent’s arguments are summarized below. The Respondent notes that he operates the disputed domain names as independent informational and review websites about third-party modified applications created by independent developers entirely unrelated to either the Complainant or the Respondent. These applications have existed publicly for many years and have been downloaded hundreds of millions of times globally. The Respondent’s websites provide informational overviews of these applications, feature comparisons between these applications and the official WhatsApp application, explicit security warnings on the risks of using third-party applications, installation guides for freely available third-party software, and explicit non-affiliation disclaimers. First, the Respondent acknowledges that the Complainant holds valid registered trademark rights in the WHATSAPP trademark and that the Panel may find the confusing similarity element satisfied given that portions of the trademark are recognizable within the disputed domain names, but he contends that the disputed domain names do not constitute typosquatting. Second, the Respondent notes that “GB WhatsApp” and “FM WhatsApp” are not the Complainant’s products and were created by independent third-party developers. The Respondent’s websites are used for information purposes, including descriptions, installation guides, version histories, comparison tables, and reviews. Both websites carry explicit disclaimer pages. Providing information and download assistance for freely available software is legitimate. The Respondent has not used the disputed domain names to compete with or impersonate the Complainant. Third, the Respondent states that he registered the disputed domain names with a clear, legitimate informational purpose and has operated them consistently with that purpose. The Respondent also notes that he does not dispute WHATSAPP’s fame. However, a trademark’s fame does not automatically render all domain names incorporating any portion of it abusive. The Complainant’s terms of service and other guidelines are not legally applicable to the Respondent. Lastly, the Respondent states that, without prejudice to his defenses and in genuine good faith to address any consumer-protection concerns, he commits to implementing some changes on his websites, including, for example, a prominent site-wide disclaimer banner and a visual redesign to reduce brand association. The Respondent also submits that the Complaint constitutes an abuse of the UDRP process amounting to Reverse Domain Name Hijacking. 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. page 4 The Panel finds that, as also acknowledged by the Respondent, the WHATSAPP trademark is recognizable within the disputed domain names. The Panel notes that the first disputed domain name incorporates the WHATSAPP trademark with the omission of the second “p” and the second disputed domain name incorporates the “whats” element of the Complainant’s trademark with the replacement of the letter “s” with an “a”. In his analysis, the Panel also considers that the Top Level Domain “.app” further supports his conclusion for the confusing similarity between the WHATSAPP trademark and the disputed domain names. WIPO Overview 3.1, section 1.11.3. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. Although the addition of other terms here, “fm ” 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 names 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 names. Although the Respondent filed a Response, the Panel finds that the Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant and sufficient evidence demonstrating rights or legitimate interests in the disputed domain names such as those enumerated in the Policy or otherwise. The Panel considers that the disputed domain names, that are confusingly similar to the well-known WHATSAPP trademark and resolves to websites reproducing the said trademark and the Complainant’s design elements, falsely suggest an affiliation with the Complainant and has the potential to confuse Internet users into believing that the purported modified versions of the WhatsApp application promoted by the Respondent are operated, approved or endorsed by the Complainant, which is not the case. The Panel also finds that the websites do not prominently disclose the Respondent’s lack of relationship with the Complainant. The disclaimer found on the websites is either on the “About us” subpage or on the “Disclaimer tab”. Moreover, the Panel finds that where the overall circumstances of a case point to the respondent’s bad faith, the mere existence of a disclaimer cannot cure such bad faith. In particular, panels have held that the use of a domain name for illegitimate activity can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. In the present case, the disputed domain names are used for the illegitimate activity to promote and, among other things, to provide download assistance for an unauthorized and so-claimed modified version of the Complainant’s application in violation of the Complainant’s trademark rights. page 5 Under these circumstances, the Panel rejects the Respondent’s defenses and finds that such use of the disputed domain names does not constitute legitimate or non-commercial fair use, and 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. In the present case, it is clear that, as also accepted by the Respondent, the Respondent was aware of the Complainant’s well-known trademark when registering the disputed domain names. Panels have held that the use of a domain name for illegitimate activity, here the promotion of and provision of download assistance for an unauthorized and so-claimed modified version of the WhatsApp application by using the Complainant’s trademark, constitute bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitute bad faith under the Policy. Lastly, the Panel also finds that, by using the disputed domain names, the Respondent has intentionally attempted to attract Internet users to his websites by creating a likelihood of confusion with the WHATSAPP trademark as to the source, sponsorship, affiliation, or endorsement of these websites. Under these circumstances, the Panel rejects the Respondent’s defenses and finds that the Complainant has established the third element of the Policy. Accordingly, the Panel rejects the Respondent’s request for a finding of Reverse Domain Name Hijacking as the Panel finds no indicia suggesting the Complaint was brought in bad faith. 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 names <fmwhatsap.app> and <gbwhata.app> be transferred to the Complainant. /Mehmet Polat Kalafatoglu/ Mehmet Polat Kalafatoglu Sole Panelist Date: July 6, 2026

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

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