Meta Platforms, Inc. v. dinh truong, na

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Meta Platforms, Inc. v. dinh truong, na

Case No. D2026-2829

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 dinh truong, na, Viet Nam.

2. The Domain Names and Registrar

The disputed domain names <noreplybusinesfacebook.com> and <noreplybussinesfacebook.com> are registered with Dynadot Inc (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 29, 2026. On June 30, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On July 1, 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, Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 7, 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 14, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 3, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 9, 2026.

The Center appointed Daniel Peña as the sole panelist in this matter on August 12, 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 Meta Platforms, Inc., a United States-based social technology company that operates Facebook, Instagram, Meta Quest, and WhatsApp, among other platforms. The Complainant rebranded under the “Meta” name on October 28, 2021.

The Complainant's Facebook platform, founded in 2004, is a leading global provider of online social-media and social-networking services. The Facebook platform has approximately 3.07 billion monthly active users and 2.11 billion daily active users worldwide as of December 31, 2025, with services available in over 70 languages. The FACEBOOK brand ranked 19th in Interbrand’s Best Global Brands report for 2025.

The Complainant maintains a significant online presence, including numerous domain name registrations incorporating the FACEBOOK mark across various gTLDs and ccTLDs, as well as substantial followings on major social-media platforms. The Complainant also operates Meta Business (formerly “Facebook for Business”), a platform for businesses, advertisers, and creators, accessible through the subdomain <business.facebook.com>.

The Complainant holds registered trademark rights in FACEBOOK in numerous jurisdictions worldwide, including United States Trademark Registration No. 3,734,637 (registered January 5, 2010), International Registration No. 1075094 (registered July 16, 2010), and European Union Trade Mark Nos. 005585518 and 009151192 (registered May 25, 2011 and December 17, 2010 respectively).

The disputed domain names are <noreplybusinesfacebook.com> and <noreplybussinesfacebook.com>, both of which incorporate the Complainant’s FACEBOOK mark preceded by the terms “noreply” and misspellings of “business”. Both domain names were registered in May 2026, and resolve to inactive web pages. The Complainant attempted to resolve the dispute amicably by submitting registrar contact form notices on June 11, 2026, but received no response.

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.

Notably, the Complainant asserts rights in the FACEBOOK trademark through numerous worldwide registrations and submits that the disputed domain names are confusingly similar to its mark, as FACEBOOK is entirely and recognizably incorporated within both domain names. The addition of the terms “noreply” and misspellings of “business” does not prevent a finding of confusing similarity, and the gTLD “.com” may be disregarded as a standard registration requirement.

The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain names. The Respondent is not affiliated with or authorized by the Complainant. Both disputed domain names resolve to inactive web pages, with no evidence of use in connection with a bona fide offering of goods or services or of demonstrable preparations for any legitimate use. There is no evidence that the Respondent is commonly known by the disputed domain names or holds any relevant trademark rights. The Complainant argues that the composition of the disputed domain names — combining the FACEBOOK mark with ”noreply” and “business” — falsely suggests affiliation with the Complainant’s platform and cannot constitute fair use, thereby establishing a prima facie case shifting the burden of production to the

Respondent.

The Complainant contends that the FACEBOOK mark is globally famous and that the Respondent must have had knowledge of the mark at the time of registration. The disputed domain names were registered without authorization, with the intent to create a misleading impression of affiliation. The Respondent’s use of a privacy proxy service and failure to respond to pre-complaint notices are cited as further indicia of bad faith. Invoking the passive holding doctrine, the Complainant submits that the mark’s reputation, the Respondent’s failure to demonstrate any good-faith use, and the concealment of identity all support a finding of bad faith use. The Complainant also highlights the risk that the disputed domain names could be used for phishing, given their composition mimicking the Complainant’s business communication infrastructure, and submits that the Respondent’s continued possession constitutes an abusive threat.

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 of paragraph 4(a) of the Policy 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. See 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. The record establishes that the Complainant is the owner of numerous trademark registrations for FACEBOOK in jurisdictions throughout the world. Where a complainant holds a nationally or regionally registered trademark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case. WIPO Overview 3.1, section 1.2.1.

Turning to the comparison between the mark and the disputed domain names, the Panel finds that the FACEBOOK mark is reproduced in its entirety and remains clearly recognizable within each of the disputed domain names <noreplybusinesfacebook.com> and <noreplybussinesfacebook.com>. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7.

Although the disputed domain names incorporate additional terms — namely the prefix “noreply” together with either the misspelled term ”business” or ”business” preceding the FACEBOOK mark — the Panel finds that 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. It is well established that, where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, meaningless, or otherwise) does not preclude a finding of confusing similarity under the first element. The apparent misspellings of the term “business” as ”business” and ”business” likewise do not preclude such a finding; a domain name that consists of a common, obvious, or intentional misspelling of a term appended to a mark is confusingly similar to the relevant mark for purposes of the first element where, as here, the mark itself is recognizable in the disputed domain names. WIPO Overview 3.1, section 1.9.

The generic Top-Level Domain, here “.com”, is a standard registration requirement and, as such, may be disregarded for purposes of assessing confusing similarity under the first element. WIPO Overview 3.1, section 1.11.

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 non-exhaustive list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name, namely: (i) before any notice of the dispute, use of, or demonstrable preparations to use, the domain name in connection with a bona fide offering of goods or services; (ii) the respondent being commonly known by the domain name, even if it has acquired no trademark or service mark rights; or (iii) the respondent making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark at issue.

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 Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain names. 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 names such as those enumerated in paragraph 4(c) of the Policy or otherwise.

With respect to paragraph 4(c)(i) of the Policy, the record contains no evidence that, before any notice of the dispute, the Respondent used, or made demonstrable preparations to use, the disputed domain names in connection with a bona fide offering of goods or services. The Respondent is not a licensee of the Complainant, is not affiliated with the Complainant in any way, and has not been authorized by the Complainant to make any use of the FACEBOOK mark, whether in a domain name or otherwise. Both disputed domain names resolve to inactive web pages, and there is no evidence in the record of any business formation-related preparations, credible investment in website development, promotional materials, genuine business plan, or other indicia consistent with a bona fide use of the disputed domain names. Panels have consistently held that the mere passive holding of a domain name that is confusingly similar to a well-known trademark and has been registered without authorization does not amount to a bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy. WIPO Overview 3.1, section 2.2.

With respect to paragraph 4(c)(ii) of the Policy, there is no evidence in the record to suggest that the Respondent has been commonly known by the disputed domain names, or by a name corresponding to the disputed domain names. The disputed domain names were initially registered through a privacy proxy service, and the underlying registrant subsequently disclosed by the Registrar — “dinh truong, na” — bears no resemblance to the disputed domain names or to the FACEBOOK mark. There is likewise no evidence that the Respondent holds any trademark or service mark rights in ”facebook”, “noreplybusinesfacebook”, “noreplybussinesfacebook”, or any variation thereof. WIPO Overview 3.1, section 2.3.

With respect to paragraph 4(c)(iii) of the Policy, the Panel finds no basis on which to conclude that the Respondent is making a legitimate noncommercial or fair use of the disputed domain names, without intent for commercial gain to misleadingly divert consumers or to tarnish the mark. The disputed domain names resolve to inactive web pages, and panels have consistently held that, absent contrary evidence from the respondent, the passive holding of a domain name does not constitute legitimate noncommercial or fair use. WIPO Overview 3.1, section 2.5.

Moreover, a core consideration under the second element is whether the composition of a domain name effectively impersonates or falsely suggests sponsorship, affiliation, or endorsement by the trademark owner. WIPO Overview 3.1, section 2.5.1. In the present case, the disputed domain names reproduce the Complainant's FACEBOOK mark in its entirety and pair it with the prefix ”noreply” and the misspelled terms “business” or “business”. The terms “busines” and “bussines” — obvious misspellings of “business” — are apt to be read by Internet users as a reference to the Complainant’s Meta Business platform, which the Complainant operates through the subdomain <business.facebook.com>. The prefix “noreply” is apt to be read as a reference to the automated communications, customer service, or Help Center functions commonly associated with the Complainant’s platforms. The Panel therefore finds that the composition of the disputed domain names carries a risk of implied affiliation with the Complainant and cannot support a claim of fair use. WIPO Overview 3.1, section 2.5.1.

The Respondent’s use of a privacy proxy service to shield its identity at the time of registration, together with the Respondent's failure to respond to the Complainant’s pre-Complaint Registrar contact form notices and its default in these proceedings, reinforce the Panel’s conclusion that no legitimate interest can be inferred from the record.

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. These circumstances are non- exhaustive, and other circumstances may also 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.

Turning first to the question of registration in bad faith, the Panel finds that the Complainant’s FACEBOOK mark is highly distinctive and enjoys a strong reputation worldwide. The mark has been used continuously and extensively in connection with the Complainant’s social-networking services since 2004, and the Facebook platform has approximately 3.07 billion monthly active users and 2.11 billion daily active users worldwide as of December 31, 2025, with services available in more than 70 languages. The Complainant’s registered trademark rights in FACEBOOK, dating back as early as 2010, substantially predate the registration of the disputed domain names in May 2026. Prior UDRP panels have repeatedly recognized the strength and renown of the FACEBOOK mark and have inferred that respondents registering domain names incorporating that mark did so with knowledge of the Complainant and its rights.

The Panel further notes that the disputed domain names reproduce the FACEBOOK mark in its entirety, combined with the prefix ”noreply” and the misspelled terms ”business” or ”business”, under the “.com” gTLD. The terms ”business” and ”business” are apt to be read as a reference to the Complainant’s Meta Business platform, operated through the subdomain <business.facebook.com>, while the term ”noreply” is apt to be read as a reference to the Complainant's automated communications and support services. Given the fame of the FACEBOOK mark and the composition of the disputed domain names, the Panel finds it implausible that the Respondent registered the disputed domain names without knowledge of the Complainant and its rights, and concludes that the Respondent registered them with the Complainant’s mark in mind and with the intention of creating a false impression of association with the Complainant. The Panel accordingly finds that the disputed domain names were registered in bad faith.

Turning to the question of use in bad faith, the Panel notes that the disputed domain names resolve to inactive web pages. Panels 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. To the contrary, in looking at the totality of the circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for the purposes of the Policy. WIPO Overview 3.1, section 3.3. Factors relevant to the application of the passive holding doctrine include the degree of distinctiveness or reputation of the complainant’s mark, the failure of the

respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, and the respondent’s taking active steps to conceal its identity.

The Panel finds that each of these factors is present here: (i) the Complainant’s FACEBOOK mark is highly distinctive and enjoys a substantial reputation worldwide, being associated with the world’s leading provider of online social-media and social-networking services. (ii) the Respondent has failed to come forward with any response in these proceedings, and there is no evidence of any actual or contemplated good-faith use of the disputed domain names. (iii) the Respondent registered the disputed domain names using a privacy proxy service, thereby taking active steps to conceal its identity. In addition, the Respondent failed to respond to the Complaint. . The Panel notes that no good-faith use to which the disputed domain names could plausibly be put would be legitimate, given that any such use would carry a risk of implied affiliation with the Complainant and, in light of the disputed domain names’ composition mimicking the Complainant’s business communication infrastructure, a corresponding risk of use for phishing or other fraudulent activity.

In these circumstances, and considering the totality of the circumstances, the Panel finds that the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy, and that the Respondent has both registered and is using the disputed domain names in bad faith.

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 names <noreplybusinesfacebook.com> and <noreplybussinesfacebook.com> be transferred to the Complainant.

/Daniel Peña/

Daniel Peña

Sole Panelist

Date: August 22, 2026

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