DECISION

 

Snap Inc. v. Host Master / Njalla Okta LLC

Claim Number: FA2602002206081

 

PARTIES

Complainant is Snap Inc. ("Complainant"), represented by Brianna D. Khong of Kilpatrick Townsend & Stockton LLP, California, USA. Respondent is Host Master / Njalla Okta LLC ("Respondent"), Saint Kitts and Nevis.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <snap-hack.net>, registered with Tucows Domains Inc.

 

PANEL

The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.

 

Petter Rindforth as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on February 18, 2026; Forum received payment on February 18, 2026.

 

On February 19, 2026, Tucows Domains Inc. confirmed by e-mail to Forum that the <snap-hack.net> domain name is registered with Tucows Domains Inc. and that Respondent is the current registrant of the name. Tucows Domains Inc. has verified that Respondent is bound by the Tucows Domains Inc. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").

 

On February 25, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 17, 2026 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@snap-hack.net. Also on February 25, 2026, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.

 

Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.

 

On March 18, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Petter Rindforth as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant is the owner of the SNAPCHAT and SNAP trademarks. Complainant owns and distributes the SNAPCHAT camera and messaging application, and storytelling platform—available for both the iOS and Android operating systems—that, among other things, allows users to share photographs, videos, and messages called "Snaps" with others via mobile devices (the "Snapchat App").

 

Since its launch in 2011, the Snapchat App has been one of the fastest growing and most popular smartphone applications in the world.  On September 24, 2016, Complainant changed its name from Snapchat Inc. to Snap Inc., to reflect Complainant's growing list of products beyond the Snapchat App. By February 2017, the Snapchat App had an estimated 79% market share among teenagers and young adults in the United States. Due to the Snapchat App's exponential growth and immense popularity, the SNAPCHAT brand is frequently, if not daily, referenced in the media and popular culture.

 

Respondent registered the infringing domain name <snap-hack.net> on April 19, 2025, well after Complainant began using the Snap Marks. The infringing domain name does not currently resolve to an active website, but previously resolved to a website featuring the SNAPCHAT trademark in the website header "Snapchat-hack" and offering a tool to hack into other users' Snapchat accounts.

 

On May 23, 2025, Complainant's online enforcement vendor sent Respondent a cease-and-desist letter via a privacy protected contact form informing Respondent of Complainant's rights and asking Respondent to abandon and transfer the <snap-hack.net> domain to Complainant. Respondent did not reply to the letter.

 

Given Respondent's prominent use of the Snap Marks in the infringing domain name, users encountering the infringing domain name will mistakenly believe that it originates from, is associated with, or is sponsored by Complainant when that is not the case.

 

Respondent has no rights or legitimate interests in the infringing domain name, and the infringing domain name is registered and is being used in bad faith. Respondent used the infringing domain name to facilitate the unlawful access and manipulation of Complainant's server, which directly competed with Complainant's services and was intended to disrupt Complainant's business in bad faith.

 

Finally, an inference of bad faith may be drawn from Respondent's prior history of improper domain name registrations given that Respondent has been involved in at least 83 domain dispute proceedings, including at least 41 proceedings in 2025 alone.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

The Complainant is the owner of a number of national and regional trademark registrations for the word trademarks SNAP and SNAPCHAT, including, but not limited to:

 

U.S. National Trademark registration No 4,345,533 SNAP (word), registered on June 4, 2013 for goods in Intl Class 9;

U.S. National Trademark registration No 4,375,712 SNAPCHAT (word), registered on July 30, 2013 for goods in Intl Class 9; and

European Union Trade Mark Registration No 011827334 SNAPCHAT (word), registered October 16, 2013 for goods and services in Intl Classes 9, 38, and 45.

 

Respondent registered the <snap-hack.net> domain name on April 19, 2025.

 

DISCUSSION

Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable."

 

Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

 

(1)       the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and

(2)       Respondent has no rights or legitimate interests in respect of the domain name; and

(3)       the domain name has been registered and is being used in bad faith.

 

In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules.  The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint").

 

Identical and/or Confusingly Similar

The Complainant asserts rights in the SNAP and SNAPCHAT trademarks based on registration of the trademarks with numerous trademark agencies around the world (e.g. U.S. National Trademark registration No 4,345,533, registered on June 4, 2013 and European Union Trade Mark Registration No 011827334, registered October 16, 2013). Registration of a trademark with multiple trademark agencies is sufficient to establish rights in the trademark. See Alibaba Group Holding Limited v. YINGFENG WANG, FA 1568531 (Forum Aug. 21, 2014) ("Complainant has rights in the ALIBABA mark under the Policy through registration with trademark authorities in numerous countries around the world."). Accordingly, the Panel find that Complainant has established rights in the SNAP and SNAPCHAT trademarks for the purposes of Policy ¶ 4(a)(i).

 

Next, Complainant argues that Respondent's <snap-hack.net> domain name is confusingly similar to Complainant's trademarks. The Panel agrees with this conclusion. The disputed domain name clearly starts with Complainant's trademark SNAP, followed by a hyphen, the word "hack", and the gTLD .net. The word "hack" does nothing to distinguish the disputed domain name from Complainant's trademark. If noted at all, it is a word related to unfair use of Internet services ("hacking"), and the full disputed domain name may well be understood as the sentence "SNAP hacks the Internet". The disputed domain name is less similar to Complainant's trademark SNAPCHAT, but still created in a way that make references to Complainant's services.

 

The Panel therefore finds that the disputed domain name <snap-hack.net> is confusingly similar to – at least - the SNAP trademark under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Once the Complainant makes a prima facie case in support of its allegations in respect of the second element of the Policy, the burden shifts to the Respondent to show that it does have rights or legitimate interests pursuant to Policy ¶ 4(a)(ii). See AOL LLC v. Gerberg, FA 780200 (Forum Sept. 25, 2006) ("Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names.").

 

Complainant argues that Respondent lacks rights or legitimate interests in the <snap-hack.net> domain name. Respondent is not commonly known by the disputed domain name and Respondent has no right to own or use any domain name containing Complainant's trademarks. WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name under Policy ¶ 4(c)(ii). See Amazon Technologies, Inc. v. LY Ta, FA 1789106 (Forum June 21, 2018) (concluding a respondent has no rights or legitimate interests in a disputed domain name where the complainant asserted it did not authorize the respondent to use the trademark, and the relevant WHOIS information indicated the respondent is not commonly known by the domain name). Additionally, lack of authorization to use a complainant's trademark may indicate that the respondent is not commonly known by the disputed domain name. See Emerson Electric Co. v. golden humble / golden globals, FA 1787128 (Forum June 11, 2018) ("lack of evidence in the record to indicate a respondent is authorized to use [the] complainant's mark may support a finding that [the] respondent does not have rights or legitimate interests in the disputed domain name per Policy ¶ 4(c)(ii)"). The WHOIS information for the disputed domain name lists the registrant as "Host Master / Njalla Okta LLC" and there is no other evidence to suggest that Respondent is authorized to use the SNAP (or SNAPCHAT) trademark. Therefore, the Panel find that Respondent is not commonly known by the disputed domain name per Policy ¶ 4(c)(ii).

 

The Complainant next argues Respondent fails to use the <snap-hack.net> domain name in connection with a bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, Respondent - at least before Respondents initial warning / cease and desist letter - used the infringing domain name to facilitate the unlawful access and manipulation of Complainant's server, which directly competed with Complainant's services and was intended to disrupt Complainant's business in bad faith.

 

Such use is definitely no ground for "Legitimate Interest". The Panel therefore finds that Respondent's use does not amount to a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) or (iii).

 

Registration and Use in Bad Faith

Complainant argues that the disputed domain name was registered and is being used in bad faith, hereby referring to the fact Complainant's trademarks SNAP and SNAPCHAT are distinctive and well-known, and that Respondent has a pattern of bad faith registrations.

 

Previous findings of bad faith registration of a domain name may be evidence of bad faith under Policy ¶ 4(b)(ii). See DIRECTV, LLC v. michal restl c/o Dynadot, FA 1788826 (Forum July 5, 2018) ("The record contains evidence of Respondents previous eleven UDRP actions, all of which resulted in the transfer of the domain names, thus establishing bad faith per Policy ¶ 4(b)(ii)."). See also Abbott Laboratories v. Milen Radumilo, FA 1824865 (Forum Feb. 11, 2019) ("Respondent has been subject to a number of adverse decisions suggesting a pattern of conduct under Policy 4(b)(ii).").

 

Further, use of a domain name that is confusingly similar to a well-known mark can be evidence of bad faith under Policy ¶ 4(a)(iii). See Perot Sys. Corp. v. Perot.net, FA 95312 (Forum Aug. 29, 2000) (finding bad faith where the domain name in question is obviously connected with the complainant's well-known marks, thus creating a likelihood of confusion strictly for commercial gain).

 

As noted by the Complainant, the disputed domain name as per today seems to be inactive. However, lack of active use has no effect in supporting Respondent in this case. See VideoLink, Inc. v. Xantech Corporation, FA 1608735 (Forum May 12, 2015) ("Failure to actively use a domain name is evidence of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).").

 

The previous use of the disputed domain name is, as noted above, indeed is bad faith use, with the presuming goal to disturb the Complainant's business and/or to collect secret personal information from the users.

 

Altogether, the Panel agrees with Complainant's conclusions, and find that Respondent registered and used the disputed domain name in bad faith per Policy ¶ 4(a)(iii) and Policy ¶ 4(b)(ii).

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <snap-hack.net> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Petter Rindforth, Panelist

Dated: April 1, 2026