Westmore · UDRP DecisionFacebookplus.com
The Panel ordered transfer of <facebookplus.com> to Meta Platforms, Inc. It found the domain confusingly similar to the registered FACEBOOK mark because it incorporated the mark in full with the term “plus”; found no rights or legitimate interests after the Complainant established an unrebutted prima facie case; and found bad-faith registration and use based on the well-known mark, the domain’s composition, passive holding, the Respondent’s failure to respond to correspondence or the proceeding, and the Panel’s inference concerning use of a privacy service.
The timeline behind facebookplus.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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The decision illustrates how a domain combining a well-known mark with an ordinary additive term can satisfy confusing similarity and how passive holding may support bad faith when accompanied by the mark’s reputation, a mark-targeting domain composition, no plausible good-faith explanation, non-response, and an unrebutted privacy-service inference.
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. rin pa Case No. D2026-2973 1. The Parties The Complainant is Meta Platforms, Inc., United States of America (“United States”), represented by Hogan Lovells (Paris) LLP, France. The Respondent is rin pa, United States. 2. The Domain Name and Registrar The disputed domain name <facebookplus.com> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 7, 2026. On July 7, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 8, 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, Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 8, 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 July 9, 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 July 10, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 30, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 31, 2026. page 2 The Center appointed Evan D. Brown as the sole panelist in this matter on July 31, 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 social technology company and operates the Facebook platform. It owns the trademark FACEBOOK, and that mark is the subject of registrations in several jurisdictions, including the United States (e.g., Reg. No. 3,734,637, registered on January 5, 2010). According to the WhoIs information, the disputed domain name was registered on February 19, 2020. The disputed domain name resolves to a Registrar parking page stating: “This domain is registered at Dynadot.com. Website coming soon.” On July 2, 2026, the Complainant, through counsel, submitted a notice via the Registrar’s registrant contact form, asserting the unauthorized nature of the disputed domain name. No response was received. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain name is identical or confusingly similar to the Complainant’s trademark; that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and that the disputed domain name was registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (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. The Panel finds that all three of these elements have been met in this case. A. Identical or Confusingly Similar The first element functions primarily as a standing requirement. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. 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. Id. This element requires the Panel to consider two issues: first, whether the Complainant has rights in a relevant mark; and second, whether the disputed domain name is identical or confusingly similar to that mark. A registered trademark provides a clear indication that the rights in the mark shown on the trademark certificate belong to its respective owner. See Advance Magazine Publishers Inc., Les Publications Conde Nast S.A. v. Voguechen, WIPO Case No. D2014-0657. The Complainant has demonstrated its rights in the FACEBOOK mark by providing evidence of its trademark registrations. The disputed domain name incorporates the FACEBOOK mark in its entirety with the term “plus” which does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s FACEBOOK mark. See WIPO Overview 3.1, section 1.8. The FACEBOOK mark remains recognizable for a showing of confusing similarity under the Policy. Based on the available record, the Panel finds the first element of the Policy has been established. page 3 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. While the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the often impossible 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. 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. On this point, the Complainant asserts, among other things, that: (1) the Respondent is not a licensee of the Complainant and the Respondent is not affiliated with the Complainant in any way, (2) the Respondent is not commonly known by the disputed domain name, (3) the Respondent is not making a legitimate noncommercial or fair use of the disputed domain name, (4) the Complainant has not granted any authorization for the Respondent to make use of its FACEBOOK trademark, in a domain name or otherwise, and (5) the passive holding of the disputed domain name does not amount to use in connection with a bona fide offering of goods or services. The Panel finds that the Complainant has made the required prima facie showing. The Respondent has not presented evidence to overcome this prima facie showing, and nothing in the record otherwise tilts the balance in the Respondent’s favor. Accordingly, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Because the Complainant’s FACEBOOK mark is well known, and is registered in jurisdictions around the world, the Panel finds it likely that the Respondent was aware of the mark when it registered the disputed domain name. In the circumstances of this case, without the benefit of any explanation whatsoever from the Respondent as to a possible good faith use of the disputed domain name, such a showing is sufficient to establish bad faith registration of the disputed domain name. Meta Platforms, Inc. v. Christopher Thompson, Redstone Remodeling & Service Co. LLC, WIPO Case No. D2023-2663. The circumstances also demonstrate bad faith use of the disputed domain name in terms of the Policy. Where a disputed domain name is “so obviously connected with such a well-known name and products [...] its very use by someone with no connection with the products suggests opportunistic bad faith”. Parfums Christian Dior v. Javier Garcia Quintas, WIPO Case No. D2000-0226. Furthermore, from the inception of the UDRP, panelists have found that the non-use of a domain name (including a blank or “coming soon” page) would not by itself prevent a finding of bad faith under the doctrine of passive holding (see section 3.3 of the WIPO Overview 3.1). In this regard, the Panel notes the reputation of the FACEBOOK mark, the composition of the disputed domain name, and the Respondent’s failure to submit a response or to provide any evidence of actual or contemplated good-faith use of the disputed domain name. The lack of response by the Respondent to the notice correspondence sent by the Complainant further supports a finding of bad faith. Past UDRP panels have held that failure to respond to a cease-and-desist letter may be considered a factor in finding bad faith registration and use of a domain name. See Encyclopaedia Britannica, Inc. v. John Zuccarini and The Cupcake Patrol a/ka Country Walk a/k/a Cupcake Party, WIPO Case No. D2000-0330. Bad faith in the circumstances of this case is also confirmed from the Respondent’s use of a privacy service to register the disputed domain name. Where it appears that a respondent intentionally employs a privacy or proxy service merely to hide its identity from an anticipated complainant or to avoid being notified of a UDRP page 4 proceeding filed against it, panels tend to find that this supports an inference of bad faith; a respondent filing a response may refute such inference. WIPO Overview 3.1, section 3.6. The Respondent has not refuted such inference in this case. Accordingly, for these reasons, the Panel finds the third element of the Policy has been established. 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 <facebookplus.com> be transferred to the Complainant. /Evan D. Brown / Evan D. Brown Sole Panelist Date: August 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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