Westmore · UDRP decision
WIPO · Case No. D2025-3351

Carrefourhypermarket.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <carrefourhypermarket.com>. It found the domain confusingly similar to the Complainant’s CARREFOUR mark because it incorporated the mark in its entirety, with the additional term “hypermarket.” The Respondent did not rebut the Complainant’s prima facie showing that the Respondent lacked rights or legitimate interests. Bad faith was established based on the longstanding and well-known CARREFOUR mark, the domain’s composition, the Panel’s finding that the Respondent must have had the Complainant in mind, and passive holding through a “launching soon” website.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-10-09
Panelist(s)
Albert, Michael A.
Complainant
Carrefour SA
Respondent
Bulbul Bulbul
Counsel
IP Twins
Disputed domain(s)
carrefourhypermarket.com
Citation weightrelies on 2 authorities
Domain history UDRP Intelligence

The timeline behind carrefourhypermarket.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 carrefourhypermarket.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of carrefourhypermarket.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how a domain combining a well-known mark with a term closely associated with the trademark owner’s business can affect all three UDRP elements. Incorporation of the mark established confusing similarity; the business-related term heightened the risk of implied affiliation; and the same composition, together with longstanding rights and passive holding, supported the bad-faith finding.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-10-09
Panel
Albert, Michael A.
Full decision
7 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Carrefour SA v. Bulbul Bulbul Case No. D2025-3351 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondent is Bulbul Bulbul, United Arab Emirates. 2. The Domain Name and Registrar The disputed domain name <carrefourhypermarket.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 August 20, 2025. On August 20, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 20, 2025, 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 (Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 25, 2025, 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 26, 2025. 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 August 28, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 17, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 22, 2025. page 2 The Center appointed Michael A. Albert as the sole panelist in this matter on September 25, 2025. 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 one of the worldwide leaders in retail and claims to be a pioneer of the concept of hypermarkets since 1968. The Complainant is listed on the index of the Paris Stock Exchange (CAC 40). The Complainant operates more than 12.000 stores in more than 30 countries worldwide. With more than 384.000 employees worldwide and 1.3 million daily unique visitors in its stores, and revenue of some 76 billion euros in a recent year, the Complainant is a major and well-known worldwide leader in retail. The Complainant owns several hundred trademark rights worldwide in the CARREFOUR mark. In particular, the Complainant is the owner of the following trademarks registered well before the registration of the disputed domain name: International trademark CARREFOUR No. 351147, registered on October 2, 1968, duly renewed, and designating goods in international classes 01 to 34; International trademark CARREFOUR No. 353849, registered on February 28, 1969, duly renewed and designating services in international classes 35 to 42. The Complainant’s fame is also evidenced on the Internet, with millions of Internet users. Complainant also owns numerous domain names using its CARREFOUR trademarks, both within generic and national top- level domains. For instance, <carrefour.com> has been registered since 1995. The disputed domain name was registered on August 1, 2025, and resolves to “launching soon” website. 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 is identical or highly similar to the Complainant’s marks. The Respondent should be considered as having no rights or legitimate interests in respect of the disputed domain name. The Complainant contends that the Respondent has registered and is using the disputed domain name in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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 of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. Here, Complainant has indisputably shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms – here, “hypermarket” – may bear on assessment of the second and third elements, the 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 3.0, 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 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 3.0, 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 evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. There is no evidence that the Respondent (as an individual, business, or other organization) has been commonly known by the disputed domain name. The Respondent registered the disputed domain name which comprises the Complainant’s trademark without any license or authorization from Complainant. The nature of the disputed domain name combining the Complainant’s trademark with a term that relates to Complainant’s business, creates a risk of implied affiliation. WIPO Overview 3.0, section 2.5.1. The Panel finds the second element of the Policy has been established. page 4 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 the Complainant and its trademarks were so well-known, that it is inconceivable that the Respondent did not have the Complainant’s name and trademark in mind when registering the domain name. The Complainant’s CARREFOUR marks significantly predate the registration date of the disputed domain name. In this regard, previous Panels have established that knowledge of the Complainant’s intellectual property rights, including trademarks, at the time of registration of the disputed domain name, establishes bad faith registration (ALSTOM v. Domain Investments LLC, WIPO Case No. D2008-0287, and NBC Universal Inc. v. Szk.com / Michele Dinoia, WIPO Case No. D2007-0077). Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case, the passive holding of the disputed domain name does not prevent a finding of bad faith under the Pol ic y. 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 <carrefourhypermarket.com> be transferred to the Complainant. /Michael A. Albert/ Michael A. Albert Sole Panelist Date: October 9, 2025

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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