Westmore · UDRP DecisionCarrefoarsa.com + 5 more domains
The Panel consolidated the disputes against the nominally different registrants after finding that the six disputed domain names were under common control. It found all six domains confusingly similar to Carrefour SA's CARREFOUR mark, found no rights or legitimate interests, and concluded that the domains were registered and used in bad faith. The Panel relied on the coordinated registration pattern, misspellings of the Turkish joint venture name “CarrefourSA”, one domain's prior impersonation of the joint venture website, non-bona fide or inactive use, and passive holding in the circumstances. All six domains were ordered transferred to the Complainant.
The timeline behind carrefoarsa.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 carrefoarsa.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a panel may consolidate nominally different registrants where multiple domains show a tightly coordinated registration period, matching typographical patterns, overlapping or nearly identical registrant details, shared technical behavior, and false contact information. It also shows that inactive domains can support transfer when the broader record demonstrates deliberate targeting and includes prior impersonation by one domain in the coordinated group.
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 Carrefour SA v. Muhammad Ali Holiday, Muhammad Ali Bayram, Osmanatay komurcu, Deniz Talat, Atilla Kurt, Muhammed Ali Bayram Case No. D2025-3665 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondents are Muhammad Ali Holiday, Muhammad Ali Bayram, Türkiye, Osmanatay komurcu, United States of America (“United States”), Deniz Talat, Türkiye, and Atilla Kurt, Türkiye, Muhammed Ali Bayram, Türkiye. 2. The Domain Names and Registrars The disputed domain name <carrefoarsa.com> is registered with NameCheap, Inc. The disputed domain names <carrefoursaa.com> and <carrefoursada.com> are registered with Wix.com Ltd. The disputed domain name <carrefoursam.online> is registered with Squarespace Domains LLC. The disputed domain name <carrefourssa.com> is registered with Hostinger Operations, UAB. The disputed domain name <carrefourssa.online> is registered with Tucows Domains Inc. NameCheap, Inc., Wix.com Ltd., Squarespace Domains LLC, Hostinger Operations, UAB, and Tucows Domains Inc. are separately and collectively referred to below as the “Registrar”. 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 10, 2025. On the same day, the Center transmitted by email to the Registrar requests for registrar verification in connection with the disputed domain names. On September 10, 11, 12 and 18, 2025, the Registrar transmitted by email to the Center its verification responses disclosing registrant and contact information for the disputed domain names that differed from the named Respondent (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 19, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaints for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on September 22, 2025 in which it requested consolidation of the Complaint against all the disputed domain name registrants. page 2 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 Respondents of the Complaint, and the proceedings commenced on September 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 13, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on October 23, 2025. The Center appointed Matthew Kennedy as the sole panelist in this matter on October 24, 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 a retailer that operates more than 14,000 stores in more than 40 countries worldwide, including Türkiye. It has more than 500,000 employees worldwide and millions of daily unique visitors in its stores. The Complainant holds multiple trademark registrations in multiple jurisdictions, including the following: − International trademark number 351147 for CARREFOUR, registered on October 2, 1968, specifying goods in classes 1 to 34; − International trademark number 353849 for CARREFOUR, registered on February 28, 1969, specifying services in classes 35 to 42; and − European Union trademark registration number 005178371 for CARREFOUR, registered on August 30, 2007, specifying goods and services in classes 9, 35 and 38. The above trademark registrations are current. The Complainant has also registered multiple domain names, including <carrefour.com> (registered on October 25, 1995), that it uses in connection with a website in French and English where it provides information about its corporate group. The Complainant participates in a joint venture in Türkiye named “CarrefourSA”, which uses the domain name <carrefoursa.com> in connection with an online store in Turkish. That site prominently displays the CARREFOUR mark with a “C” device (the “Carrefour logo”). The Complainant is active on social media; its Facebook page has more than 11 million likes. The disputed domain names were registered on the dates and in the names set out below: Date of registration Disputed domain name Registrant August 17, 2025 <carrefourssa.com> Atilla Kurt August 20, 2025 <carrefoarsa.com> Deniz Talat August 21, 2025 <carrefoursaa.com> Muhammed Ali Bayram August 21, 2025 <carrefoursada.com> Muhammed Ali Bayram August 21, 2025 <carrefourssa.online> Muhammad Ali Holiday, Muhammad Ali Bayram August 22, 2025 <carrefoursam.online> Osmanatay komurcu The disputed domain name <carrefourssa.com> formerly resolved to a webpage offering for sale a football jersey on a Turkish e-commerce platform, and displaying information about the Istanbul travel card. Two weeks later, it resolved to a website in Turkish titled “ÉliteFilms”, ostensibly offering films for streaming but page 3 including at least some hyperlinks that did not function. At the time of this Decision, it resolves to a default landing page provided by the Registrar. The disputed domain names <carrefoarsa.com> and <carrefourssa.online> resolve or formerly resolved to a web server default page because they were not associated with active websites. The disputed domain names <carrefoursaa.com> and <carrefoursada.com> may have never resolved to active websites either. The disputed domain name <carrefoursam.online> initially resolved to an e-commerce website in Turkish displaying the Complainant’s CARREFOUR logo and offering household items for sale. Later, it ceased to resolve to any active 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 names. Notably, the Complainant contends that the disputed domain names are confusingly similar to its CARREFOUR mark. The Respondents have no rights or legitimate interests in the disputed domain names. The Complainant has not authorized the use of its CARREFOUR trademarks or terms similar thereto in the disputed domain names in any manner or form. Four disputed domain names resolve to error pages, one resolves to a standard landing page, and the sixth hosted a website impersonating the Complainant. One disputed domain name formerly resolved to a film website that seemed like a quick cut-and-paste operation replacing a completely different website in less than a month since its first registration. The disputed domain names have been registered and are being used in bad faith. The Complainant and its trademarks are so widely well-known that it is inconceivable that the Respondents ignored them. It is highly likely that the Respondents chose the disputed domain names because of their similarity to a trademark in which the Complainant has rights and legitimate interests. Five of the disputed domain names currently do not resolve to any active website but their non-use does not prevent a finding of bad faith under the doctrine of passive holding. There is also evidence that one of these disputed domain names (<carrefoursam.online>) was used to impersonate the Complainant while another (<carrefourssa.com>) can only be described as a typographical error. B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or entity, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on the Complainant’s request. page 4 Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.11.2. As regards common control, the Panel notes that two disputed domain names are held in the same name (i.e., Muhammed Ali Bayram), which is almost identical to the name of the registrant organization (Muhammad Ali Bayram) for another disputed domain name. All disputed domain names were registered within less than a week; all disputed domain names share a similar naming pattern; two disputed domain names share the same operational element (“carrefourssa”); and two disputed domain names (<carrefoarsa.com> and <carrefourssa.online>) resolved to the same landing page even though they were held by nominally different registrants. The United States contact details for one disputed domain name (<carrefoursam.online>) are at least partly false. In view of these circumstances, the Panel is persuaded that the disputed domain names are under common control. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. 6.2 Substantive Issues Paragraph 4(a) of the Policy provides that a complainant must demonstrate each of the following elements: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark 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. The burden of proof of each element is borne by the Complainant. 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. See WIPO Overview 3.0, section 1.7. The Complainant has shown rights in respect of the CARREFOUR trademark for the purposes of the Policy. See WIPO Overview 3.0, section 1.2.1. Five disputed domain names wholly incorporate the CARREFOUR mark as their respective initial element. Despite the addition of letters after the mark (variously “ssa”, “saa”, “sada”, or “sam”), the mark remains clearly recognizable within these disputed domain names. The other disputed domain name (<carrefoarsa.com>) contains an obvious misspelling of the CARREFOUR mark, differing in the substitution of an “a” for the “u”, and followed by the letters “sa”. Despite these differences, this disputed domain name contains sufficiently recognizable elements of the mark. The only additional element in each disputed domain name is a generic Top-Level Domain (“gTLD”) extension (variously “.com” or “.online”) which, as a standard requirement of domain name registration, may be disregarded in the assessment of confusing similarity for the purposes of the Policy. Accordingly, the disputed domain names are confusingly similar to page 5 the CARREFOUR mark for the purposes of the Policy. See WIPO Overview 3.0, sections 1.7, 1.8, 1.9, and 1.11.1. Therefore, 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. See WIPO Overview 3.0, section 2.1. In the present case, the disputed domain name <carrefourssa.com> resolved to a website ostensibly offering films for streaming at the time when the Complaint was filed. Some resources were missing, at least some hyperlinks on the website did not function, and it had rapidly replaced an entirely unrelated webpage that had displayed an item for sale with random information. Nothing on either the website or the previous webpage had any apparent relationship to the disputed domain name. Given that this disputed domain name was registered within days of the others, and all are misspellings of the name of the Complainant’s Turkish joint venture “CarrefourSA”, and that this disputed domain name has since ceased to resolve to an active website, the Panel finds it more likely than not that the film website was not bona fide. The other five disputed domain names were not associated with any active website at the time when the Complaint was filed. These circumstances do not constitute a use of any of the disputed domain names in connection with a bona fide offering of goods or services, nor a legitimate noncommercial or fair use for the purposes of the Policy. Further, the Registrar has verified that the Respondent is identified in the WhoIs database by the names shown in Section 1 above, none of which resembles any disputed domain name. Nothing on the record indicates that the Respondent has been commonly known by any of the disputed domain names. 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 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 the Policy or otherwise. Based on the record, the Panel finds the second element of the Policy has been established. C. Registered and Used 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. See WIPO Overview 3.0, section 3.2.1. In the present case, the disputed domain names were registered in 2025, decades after the registrations of the Complainant’s CARREFOUR mark. Five disputed domain names wholly incorporate that mark as their initial element while one includes an obvious misspelling of that mark. All six disputed domain names are misspellings of the name of the Complainant’s Turkish joint venture “CarrefourSA”, either duplicating the “s” or the “a”, substituting an “a” for the “u”, or adding an “m” or the letters “da”. One disputed domain name (<carrefoursam.online>) formerly resolved to a website that prominently displayed the Complainant’s page 6 CARREFOUR logo. The Respondent provides no explanation for its choice of the disputed domain names. In view of these circumstances, the Panel finds that the Respondent registered the disputed domain names with the Complainant’s CARREFOUR mark in mind. As regards use, only one of the disputed domain names resolved to an active website at the time when the Complaint was filed but the Panel has found in Section 6.2B above that this website was not bona fide. At the time of this Decision, none of the disputed domain names resolves to an active website. However, prior UDRP panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. See WIPO Overview 3.0, section 3.3. In the present case, the Complainant’s CARREFOUR trademark enjoys a strong reputation in relation to retail services due to its widespread and longstanding use both online and offline. One of the disputed domain names (<carrefoursam.online>) initially resolved to a website impersonating the Complainant’s Turkish joint venture website. The composition of all disputed domain names appears to have no other purpose than to divert Internet users who misspell the name of the Complainant’s Turkish joint venture “CarrefourSA” in an Internet browser. These are all indications of bad faith. Having reviewed the available record, the Panel finds that in the circumstances of this case the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy. Therefore, 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 <carrefoarsa.com>, <carrefoursaa.com>, <carrefoursada.com>, <carrefoursam.online>, <carrefourssa.com> and <carrefourssa.online> be transferred to the Complainant. /Matthew Kennedy/ Matthew Kennedy Sole Panelist Date: November 3, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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