Westmore · UDRP DecisionFacebookmethod.com
The Panel ordered the transfer of <facebookmethod.com> to Meta Platforms, Inc. Although the Respondent informally consented to transfer, the Panel issued a substantive decision because the Complainant had not requested suspension for settlement, the Respondent had not explained its failure to answer the cease-and-desist letter, and the Respondent disclaimed bad faith. The Panel found the domain confusingly similar to the FACEBOOK mark, found no rights or legitimate interests because the commercial training site used the mark, modified Facebook and Instagram logos, and related visual elements beyond what was reasonably necessary, and found bad-faith targeting for commercial gain under paragraph 4(b)(iv) of the Policy.
The timeline behind facebookmethod.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 facebookmethod.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that a commercial educational or training service about a trademark owner’s platform does not automatically acquire a legitimate interest in a domain incorporating the mark. The overall presentation mattered: use of the entire FACEBOOK mark, modified platform logos, related visual branding, paid services, and a minimally displayed disclaimer collectively supported findings of unfair use and intentional commercial targeting. It also shows that consent to transfer may not end substantive review where the respondent disclaims bad faith and the complainant does not seek suspension for settlement.
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. Pedro Madaleno, peter matt Case No. D2026-3531 1. The Parties The Complainant is Meta Platforms, Inc., United States of America (“United States”), represented by Hogan Lovells Cadwalader (Paris) LLP, France. The Respondent is Pedro Madaleno, peter matt, Portugal. 2. The Domain Name and Registrar The disputed domain name <facebookmethod.com> is registered with Name.com, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 17, 2026. On August 18, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 19, 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, Domain Protection Services, Inc.) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 25, 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 August 28, 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 September 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 27, 2026. The Respondent sent email communications to the Center on August 28, 2026, and September 7, 2026. The Center informed the Parties of the commencement of the panel appointment process on September 28, 2026. page 2 The Center appointed Fabrizio Bedarida as the sole panelist in this matter on October 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 in these proceedings is Meta Platforms, Inc. (formerly Facebook, Inc.), a United States corporation. The Complainant is a technology company, and operates, inter alia, Facebook, Instagram, Meta Quest (formerly Oculus) and WhatsApp. Founded in 2004, the Complainant’s Facebook platform is a leading provider of online social media and social networking services. The Complainant owns several trademarks corresponding to and/or including FACEBOOK. The Complainant is, inter alia, the owner of: - United States registration number 3041791, for the FACEBOOK trademark registered on January 10, 2006; - United States registration number 3122052, for the FACEBOOK trademark registered on July 25, 2006; - International trademark registration number 1075094 for the FACEBOOK (device) trademark registered on July 16, 2010; and - European Union Trademark registration number 005585518, for the FACEBOOK trademark registered on May 25, 2011. In addition, the Complainant is the holder of numerous domain names consisting of or including its FACEBOOK trademark, registered under various generic Top-Level Domains (“gTLDs”) as well as under a number of country-code Top-Level Domains (“ccTLDs”), including <facebook.com>, <facebook.us> (registered on May 5, 2004), and <facebook.cn> (registered on March 4, 2005). The Complainant has also established a strong social media presence online by being active on various social-media platforms. The disputed domain name was registered on April 17, 2026. Currently the disputed domain name appears to be inactive. However, from the submissions of the Complainant, it appears that previously (at least on August 10, 2026) the disputed domain name resolved to a website that purported to provide users with methods, strategies, and training materials, which were aimed at generating leads and sales through the Complainant’s Facebook and Instagram platforms, through various pricing packages. The Respondent’s website also made references to the Complainant’s FACEBOOK trademark, and its other app, Instagram, and featured a logo at the top, combining modified versions of Facebook’s and Instagram’s distinctive logos and figurative trademarks. The Respondent’s website contained the following disclaimer: “This site is not a part of the Facebook website or Facebook Inc. Additionally, This site is NOT endorsed by Facebook in any way. FACEBOOK is a trade mark of FACEBOOK, Inc. [...]”. On June 19, 2026, the Complainant’s lawyers, in an attempt to resolve the matter amicably, sent a cease- and-desist letter to the Respondent using the email address displayed on the Respondent’s website. No response was received. page 3 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 addition of the term “method” does not prevent a finding of confusing similarity with the Complainant’s FACEBOOK trademark, which remains clearly recognizable in the disputed domain name. In addition, the Complainant affirms that the Respondent is using the disputed domain name to divert Internet users to its website, which purports to offer paid coaching and training packages relating to Facebook and Instagram marketing. In addition, the Complainant asserts that the Respondent’s website does not prominently disclose its lack of any relationship with the Complainant. Despite the disclaimer noted above, which appears only in the footer in a relatively small font, the Respondent’s website adopts a pink-to -purple gradient colour scheme closely resembling that of the Complainant’s Instagram platform and features a logo combining modified versions of the Complainant’s FACEBOOK and Instagram figurative trademarks. Taken together, these factors are likely to create the false impression that the Respondent’s website is affiliated with, or otherwise endorsed by, the Complainant, when in fact no such relationship exists. The Complainant thus concludes that the Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy. The Complainant also claims that, given the fame of the FACEBOOK trademark, it may be inferred that the Respondent registered the disputed domain name with knowledge of the Complainant’s trademark and did so in bad faith. In the circumstances of the present case, the Complainant further submits that the Respondent’s registration of the disputed domain name using a privacy service to mask its identity and its failure to respond to the Complainant's cease and desist letter constitute further evidence of bad faith. Finally, the Complainant submits that, even if the disclaimer were accurate and prominently displayed on the Respondent’s website, it would not remedy the Respondent’s illegitimate use of the disputed domain name in light of the overall circumstances of the case. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. However, the Respondent sent two informal emails to the Center, where in brief it affirmed that: When it registered the disputed domain name, it was not aware that using the word “Facebook” within a domain name could create a trademark issue; it did not register the disputed domain name with the intention of infringing the Complainant’s rights, impersonating the Complainant, or misleading anyone into believing that the Respondent was officially affiliated with the Complainant or Facebook; and the disputed domain name was simply used in connection with independent educational and marketing training relating to the Facebook platform. The Respondent concluded by noting that it no longer uses th e disputed domain name and has no interest in disputing ownership of it or continuing to use it. The Respondent stated that it does not wish to contest the Complaint and it consents to the transfer of the disputed domain name to the Complainant, and that it is willing to cooperate fully with the Complainant, and the Registrar to complete the transfer. page 4 6. Discussion and Findings 6.1. Consent to Transfer The Panel notes the Respondent’s consent but deems it appropriate to proceed to a substantive decision on the merits, mainly for the following reasons: firstly, the Complainant did not request a suspension of proceedings in order to settle; secondly, the Respondent did not deny receiving the Complainant’s cease and desist letter, nor did it explain why it did not respond to the same or why it waited until the present proceedings was brought to acknowledge the Complainant’s rights and to offer the transfer of the disputed domain name; and lastly, the Respondent disclaimed any bad faith. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.10. 6.2. Substantive Matters In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the three following elements is satisfied: (i) the disputed domain name is identical or confusingly similar to a trademark in which the Complainant has rights; and (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 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 and recognizable 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, “method”, may bear on assessment of the second and third elements, t he 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. page 5 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 Respondent offered paid coaching and training packages under a domain name incorporating the Complainant’s FACEBOOK trademark in its entirety. The associated website also used modified versions of the Complainant’s FACEBOOK and Instagram logos and visual elements of the Complainant’s colour scheme. Although the website contained a disclaimer, it appeared in a small font in the footer. The Panel, therefore, finds that the Respondent’s use went beyond what was reasonably necessary to describe the subject matter of its training services and was not bona fide or otherwise fair for purposes of the Policy. 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 given the contents displayed on the Respondent’s website, the substantial presence established worldwide and on the Internet by the Complainant, and considering the composition of the disputed domain name, it is at the least very unlikely that the Respondent was not aware of the existence of the Complainant, or of the Complainant’s trademarks, when registering the disputed domain name. Prior UDRP panels have repeatedly recognized the strength and renown of the Complainant’s FACEBOOK trademark. In fact, “Facebook” is not a common or descriptive term, but one of the most renowned trademarks in the world. Therefore, it is more likely than not that the Respondent, when registering the disputed domain name, had knowledge of the Complainant’s earlier rights to the FACEBOOK 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. The content of the Respondent’s website, which made explicit reference to the Complainant’s Facebook and Instagram platforms and featured modified Complainant’s FACEBOOK and Instagram logos and the same colour scheme, while offering paid coaching and training packages relating to Facebook and Instagram marketing, is a clear inference that the Respondent intended to target - notwithstanding the asserted educational nature and disclaimer – the Complainant in order to intentionally attract, for commercial gain, Internet users, by creating a likelihood of confusion with the Complainant’s trademark as to sponsorship by, affiliation with, and/or endorsement of the Respondent’s website in accordance with paragraph 4(b)(iv) of the Policy. Although the website at the disputed domain name contained a small-font disclaimer indicating the website is not affiliated with or endorsed by the Complainant, considering the overall circumstances of this case, the Panel finds that the mere existence of such disclaimer does not change the Panel’s finding of the Respondent’s bad faith. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. page 6 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 <facebookmethod.com> be transferred to the Complainant. /Fabrizio Bedarida/ Fabrizio Bedarida Sole Panelist Date: October 9, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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