Westmore · UDRP DecisionWhatsappbutton.com
The Panel ordered transfer of <whatsappbutton.com> to WhatsApp, LLC. It found the domain confusingly similar to the WHATSAPP trademark because the mark remained recognizable despite the addition of “button.” The Respondent lacked rights or legitimate interests because the domain was used for a website displaying the Complainant’s trademark, logo, and color scheme and purportedly offering unauthorized chatbot messaging services. The same use, together with the absence of a prominent disclaimer or any plausible explanation, supported a finding that the Respondent knowingly targeted the WHATSAPP mark to attract Internet users for commercial gain through confusion.
The timeline behind whatsappbutton.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 whatsappbutton.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a famous or distinctive mark with a function-related term can satisfy all three UDRP elements when the associated website reproduces the trademark owner’s branding and offers related, unauthorized services. The website content was significant not merely as contextual evidence but as direct support for findings of passing off, lack of legitimate interests, knowledge, targeting, and commercial-gain confusion.
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. Satya G Case No. D2026-3939 1. The Parties The Complainant is WhatsApp, LLC, United States of America (“United States”), represented by Ashurst Perkins Coie US LLP, United States. The Respondent is Satya G, India. 2. The Domain Name and Registrar The disputed domain name <whatsappbutton.com> 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 September 2, 2026. On September 3, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 3, 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 September 4, 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 September 8, 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 September 9, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 29, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 30, 2026. page 2 The Center appointed Manoel J. Pereira dos Santos 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 Pursuant to the information provided in the Complaint, the Complainant is a global leader in messaging services for mobile devices. The Complainant operates the WhatsApp messaging and voice-over-Internet Protocol service and mobile application, which is being used by over two billion people in over 180 countries. WhatsApp is available in sixty different languages. In addition, the Complainant offers business users “The WhatsApp Business” app, which allows small businesses to interact with customers using tools to automate, sort, and quickly respond to messages. The Complainant also offers business users the “WhatsApp Business Platform”, to enable larger businesses to chat with customers at scale through programmatic access to WhatsApp. The Complainant’s official website for its WhatsApp messaging platform is located at the domain name <whatsapp.com>, registered on September 4, 2008. The Complainant owns and operates numerous other domain names consisting of the WHATSAPP Trademarks in various generic Top-Level Domains and country code Top-Level Domains. The Complainant is the owner of a number of trademark registrations for WHATSAPP (the “WHATSAPP trademark”), including the following representative registrations: − the United States trademark WHATSAPP with registration No. 3939463, registered on April 5, 2011 for services in International Class 42; − the European Union trademark WHATSAPP with registration No. 009986514, registered on October 25, 2011 for goods and services in International Classes 9, 38, and 42; and − the India trademark WHATSAPP with registration No. 3111463, registered on November 30, 2015 for goods and services in International Classes 9, 35, 36, 38, 42, and 45. The disputed domain name <whatsappbutton.com> was registered on July 10, 2025, and resolves to a website displaying the Complainant’s logo and color scheme, and purportedly offering unauthorized chatbot messaging services. The Respondent appears to be an individual located in India. No other relevant information about the Respondent is available. 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 wholly incorporates the Complainant’s WHATSAPP trademark and is effectively identical to the WHATSAPP trademark followed by the non- distinctive term “button”. The addition of the term “button” does not prevent a finding of confusing similarity where the relevant trademark is recognizable. Moreover, the addition of the term “button” adds to the confusing similarity because the generic word merely describes a feature of the Complainant’s WHATSAPP messaging platform, which offers interactive button functionality through its Business API and chat integrations. The Complainant relies on other panels’ decisions which have found comparable domain names to be confusingly similar to the Complainant’s WHATSAPP Trademarks. See WhatsApp LLC v. Arjun page 3 Mehta, Indian Cricket Marketing, WIPO Case DME2025-0011; WhatsApp LLC v. Shoaib Ahmed, WIPO Case D2025-4231; WhatsApp LLC v. Krishan Gahlot, Krishan Gahlot, WIPO Case D2022-2080. The generic Top-Level Domain “.com” may be disregarded for the purposes of the confusing-similarity assessment under the first element as it is a standard registration requirement. The Complainant also points out that the content of the website to which the disputed domain name resolves is fully branded website displaying the Complainant’s logo and color scheme, and purportedly offering unauthorized chatbot messaging services. The Complainant contends that the Respondent’s website content makes it clear they have sought to target Complainant’s trademarks through the disputed domain name. The Complainant further argues that 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 independent of the Complainant’s trademark rights. The Complainant also contends that the Respondent has neither acquired nor applied for a trademark registration for “WHATSAPP BUTTON” or any variation thereof as reflected in the disputed domain name. The Complainant asserts that the Respondent is not a licensee of the Complainant, nor is he affiliated with the Complainant in any way, and that the Complainant has not authorized the Respondent to make any use of its WHATSAPP trademarks, whether in a domain name or mobile app, in the use of its logos on the website, or otherwise. The Complainant relies on prior UDRP decisions finding that it cannot constitute fair use where a respondent effectively impersonates or suggests sponsorship or endorsement by the trademark owner. The Complainant states that the formulation of the disputed domain name, coupled with the Respondent’s website content specifically targeting the Complainant, entails a high risk of implied affiliation with the Complainant. The Complainant refers to the Oki Data test, set out in Oki Data Americas, Inc. v. ASD, Inc., WIPO Case D2001-0903, and discussed in WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 2.8. According to the Complainant, the Respondent’s use of the disputed domain name does not satisfy the Oki Data test. The Complainant argues that the Complainant’s Terms of Use expressly prohibit the sort of derivatively named “WhatsApp Button” or “nextChat” services that the Respondent purports to offer, and it is impossible for the Respondent to provide any bona fide services as understood within the Oki Data test, while the Respondent uses the Complainant’s trademarks in violation of the prohibitions expressly set out in Complainant’s Terms of Use. In addition, the Complainant points out that the Respondent is not providing legitimate sales or repairs in relation to a product provided by the Complainant as unauthorized third-party websites and services similar to the Respondent’s putative “WhatsApp Button” or “nextChat” services are notoriously associated with illegal activities. The Complainant adds that the Respondent does not prominently disclose their lack of relationship with the Complainant despite repeatedly making prominent use of the WHATSAPP trademark. Finally, the Complainant asserts that the Respondent knew of Complainant’s rights to the WHATSAPP trademarks when they registered the disputed domain name because the Complainant’s WHATSAPP trademark is inherently distinctive and well-known throughout the world and has been continuously and extensively used by the Complainant since 2009, it being inconceivable for the Respondent to argue that they were not aware of Complainant’s WHATSAPP trademarks when the disputed domain name was registered on July 10, 2025. In addition, the disputed domain name and the Respondent’s website content are so obviously connected with the Complainant and its WHATSAPP trademarks and services that such use by the Respondent, which has no connection to the Complainant, suggests opportunistic bad faith. The Complainant relies on other panels’ decisions on such issue. See WhatsApp Inc. v. Francisco Costa, WIPO Case D2015-0909; WhatsApp Inc. v. Michael Nelson, Grey Matter Strategies, WIPO Case D2020-1242; WhatsApp, LLC. v. ERSIN HACIOGLU, vatansoft.net, WIPO Case D2023-4176; and WhatsApp LLC v. Faisal mehmoo, WIPO Case D2025-2176. The Complainant further contends the Respondent has intentionally attempted to attract Internet users to its website by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of Respondent’s website and putative services marketed therein, in bad faith pursuant to paragraph 4(b)(iv) of the Policy, and that the Respondent’s unauthorized chatbot messaging services promoted via the disputed domain name may be used to spread malware, to page 4 enable spam, to harvest personal data from the Complainant’s platform, to steal users’ account credentials, or for other illegal activities. The Complainant requests that the disputed domain name be transferred to the Complainant. 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 3.1, section 1.7. The Complainant has shown rights in respect of the WHATSAPP trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the WHATSAPP trademark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the WHATSAPP mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here, “button”) 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. 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 disputed domain name is confusingly similar to the Complainant’s WHATSAPP trademark and has been used for a website displaying the Complainant’s trademark, logo, and color scheme, and purportedly offering unauthorized chatbot messaging services. The Respondent’s website is clearly designed to falsely suggest page 5 an affiliation with or pass itself off as being connected to the Complainant. Panels have categorically held that the use of a domain name for illegal activity (e.g., passing off or other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13. Considering the above, the Panel does not regard that the Respondent’s conduct may give rise to rights or legitimate interests in the disputed domain name under 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. 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 disputed domain name is confusingly similar to the WHATSAPP trademark, and the Respondent has used it for a website displaying the Complainant’s trademark, logo, and color scheme, and offering unauthorized chatbot messaging services without a prominent disclosure that it has not been authorized by the Complainant. The Respondent has not provided any plausible explanation for its actions. In light of these considerations, the Panel accepts that the Respondent has registered and used the disputed domain name with knowledge of the Complainant and targeting the WHATSAPP trademark in an attempt to attract, for commercial gain, Internet users to the Respondent’s website, by creating a likelihood of confusion with the Complainant’s WHATSAPP trademark as to the affiliation or endorsement of its website and of the services offered therein. 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 <whatsappbutton.com> be transferred to the Complainant. /Manoel J. Pereira dos Santos/ Manoel J. Pereira dos Santos Sole Panelist Date: October 16, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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