Westmore · UDRP decision
WIPO · Case No. D2025-3714

Sdexo.website

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <sdexo.website> to Sodexo. It found the domain confusingly similar to the well-known SODEXO mark because it omitted one letter, that the Respondent lacked rights or legitimate interests, and that registration and use were in bad faith. The domain initially displayed pay-per-click links for catering and food services, including competitors of the Complainant, and later became inactive; the Panel found that the subsequent passive holding did not prevent a bad-faith finding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-10-24
Panelist(s)
Böhner, Pascal
Complainant
Sodexo
Respondent
Italo Trentino
Counsel
Areopage
Disputed domain(s)
sdexo.website
Citation weightCited by 4 later decisions
Domain history UDRP Intelligence

The timeline behind sdexo.website

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for sdexo.website…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of sdexo.website.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates a straightforward typosquatting pattern in which a single-letter omission from a distinctive, well-known mark was combined with sector-related pay-per-click links. It is also notable that the domain became inactive after its initial commercial use; the Panel assessed the full use history and found that later passive holding did not cure the established bad-faith circumstances.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-10-24
Panel
Böhner, Pascal
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sodexo v. Italo Trentino Case No. D2025-3714 1. The Parties The Complainant is Sodexo, France, represented by Areopage, France. The Respondent is Italo Trentino, Italy. 2. The Domain Name and Registrar The disputed domain name <sdexo.website> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 12, 2025. On September 12, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 12, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that 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 16, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 6, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 9, 2025. The Center appointed Pascal Böhner as the sole panelist in this matter on October 16, 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. page 2 4. Factual Background The Complainant is a French company founded in 1966, specializing in food services and facilities management. The Complainant is one of the largest companies in the world in its sector, with 423,000 employees serving 80 million consumers daily in 45 countries. For fiscal year 2024, the Complainant's consolidated revenues reached EUR 23.8 billion. The Complainant operates under the trade name and mark SODEXO. From 1966 to 2008, the Complainant promoted its business under the mark and name SODEXHO. In 2008, the Complainant simplified the spelling to SODEXO and changed its logo accordingly. The Complainant's services include food services (restaurant and catering services to companies, hospitals, schools, universities and other organizations) and facility management services (combining reception, hospitality, cleaning and infrastructure maintenance services). The Complainant is the owner of numerous trademark registrations for SODEXO and SODEXHO worldwide, including: - European Union Trade Mark SODEXO, registration No. 008346462, filed on June 8, 2009 and registered on February 1, 2010, covering services in international classes 9, 16, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44 and 45; - International trademark registration No. 964615 for the SODEXO logo , filed on January 8, 2008, registered on January 8, 2008, , covering services in international classes 9, 16, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44 and 45, and protected in numerous countries including Italy; - International trademark registration No. 689106 for SODEXHO, filed on January 28, 1998, registered on January 28, 1998, covering services in international classes 16, 36, 37, 39, 41 and 42, and protected in numerous countries including Italy; - International trademark registration No. 694302 for the SODEXHO logo, filed on June 22, 1998, , registered on June 22, 1998, covering goods in international class 9, and protected in numerous countries including Italy. Many previous panel decisions have acknowledged the Complainant’s rights in the SODEXO mark under the UDRP and found that the mark is “well known” or a mark with a reputation in many countries in the world. The Panel has no reason to doubt this finding and considers the mark SODEXO to be well known. The Complainant also owns numerous domain names corresponding to or containing “sodexo” or “sodexho”, including <sodexo.com>, <sodexo.fr>, <sodexo.it>, and <sodexo.website>. The disputed domain name <sdexo.website> was registered on September 4, 2025. At the time of filing the Complaint, the disputed domain name resolved to a parking page displaying pay-per- click links to websites offering catering and food services, including websites of the Complainant's competitors. Today, the website under the disputed domain name resolves to an inactive 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. page 3 Identical or Confusingly Similar The Complainant asserts that the sign “sdexo” in the disputed domain name is almost identical to the Complainant's SODEXO mark. The only difference is the deletion of the first letter “o”. The Complainant contends that this constitutes an obvious misspelling of the mark SODEXO and is characteristic of typosquatting practice intended to create confusing similarity. The Complainant argues that consumers will read and/or perceive the element “sdexo” as SODEXO and, consequently, disputed domain name as “sodexo.website”, particularly given that the Complainant owns the domain name <sodexo.website>. The Complainant emphasizes that SODEXO is a purely fanciful mark with worldwide recognition and reputation. Rights or Legitimate Interests The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant states that the Respondent is unknown to the Complainant and has no rights in SODEXO as a corporate name, trade name, mark or domain name that would be prior to the Complainant's rights. The Respondent was not commonly known by the disputed domain name and has not been authorized, licensed or otherwise permitted by the Complainant to register or use the disputed domain name. Registered and Used in Bad Faith The Complainant asserts that, given the well-known character and reputation of the SODEXO mark, the Respondent knew of its existence when registering the disputed domain name. The Complainant contends that the Respondent is using the disputed domain name to exploit confusion with the SODEXO mark to attract Internet users and redirect them to websites of the Complainant's competitors offering catering and food services through pay-per-click links. The Complainant argues this constitutes an intentional attempt to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement. The Complainant further expresses concern about the potential for fraudulent use of the disputed domain name, notably for phishing. 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 of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Complainant's trademark registrations for SODEXO predate the registration of the disputed domain name and provide clear evidence of the Complainant's rights in the SODEXO mark. The Panel finds the mark is recognizable within the disputed domain name. The disputed domain name incorporates the Complainant's SODEXO mark with the omission of the first letter “o”, resulting in “sdexo”. This constitutes a misspelling of the Complainant's mark. It is well established that where a domain name consists of a common or obvious misspelling of a trademark, this is considered to be confusingly similar to the relevant mark for purposes of the first element. WIPO Overview 3.0, section 1.9. The deletion of a single letter from the Complainant's mark does not prevent a finding of page 4 confusing similarity, as the Complainant's mark remains clearly recognizable 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. The addition of the generic Top-Level Domain (“gTLD”) “.website” 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 1.11. The applicable Top Level Domain (“TLD”) in a domain name (e.g., “.com”, “.club”, “.nyc”) is to be considered as a standard registration requirement and as such, absent specific circumstances, is disregarded under the first element confusing similarity test. 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’s 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 relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The record contains no evidence that the Respondent is commonly known by the disputed domain name or has been authorized by the Complainant to use its SODEXO mark or the designation “sdexo”. There is no evidence that the Respondent has any trademark rights or other legitimate connection to the term “sdexo”. The use of the disputed domain name to resolve to a parking page displaying pay-per-click links to websites offering catering and food services, including competitors of the Complainant, does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. Panels have found that the use of a domain name to host a parked page comprising pay-per-click links does not represent a bona fide offering where such links compete with or capitalize on the reputation and goodwill of the complainant's mark or otherwise mislead Internet users. WIPO Overview 3.0, section 2.9. The composition of the disputed domain name, incorporating a clear misspelling of the Complainant's distinctive and well-known mark, further supports a finding that the Respondent lacks rights or legitimate interests. The Respondent's choice to register a domain name that is a typosquatted version of the Complainant's mark, combined with its use to redirect Internet users to competitors' websites, cannot give rise to rights or legitimate interests. The Panel finds the second element of the Policy has been established. page 5 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. Bad Faith Registration The Panel finds that the Respondent registered the disputed domain name in bad faith with knowledge of the Complainant and its SODEXO mark. The Complainant's SODEXO mark is widely recognized in the food services and facilities management sector, with operations in 45 countries including Italy, where the Respondent is located. The Complainant has provided evidence of its substantial international presence and reputation, including its listing as one of “The World's Most Admired Companies” by Fortune Magazine. The disputed domain name incorporates a clear misspelling of the Complainant's distinctive SODEXO mark through the omission of a single letter. The term SODEXO is a fanciful term coined by the Complainant and has no meaning independent of the Complainant's business. Given the distinctive and well-known nature of the mark, the Panel finds it implausible that the Respondent could have registered the disputed domain name without knowledge of the Complainant's trademark rights. The Panel concludes that the Respondent deliberately targeted the Complainant's mark when registering the disputed domain name. Bad Faith Use The evidence shows that the disputed domain name was initially used to resolve to a parking page displaying pay-per-click links to websites offering catering and food services, including services provided by the Complainant's competitors. This constitutes use in bad faith under paragraph 4(b)(iv) of the Policy. By using the disputed domain name, the Respondent intentionally attempted to attract, for commercial gain, Internet users to competitor’s websites by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of those websites. The Respondent clearly sought to capitalize on the reputation of the Complainant's mark to redirect Internet users seeking the Complainant's services to competing commercial websites, presumably generating pay-per-click revenue in the process. The Panel notes that at the time of this decision, the disputed domain name does not resolve to an active website. However, 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. In the case at hand, the Panel notes the following circumstances that support a finding of bad faith despite the current passive holding of the disputed domain name: (a) The Complainant's SODEXO mark is distinctive and has a strong reputation internationally; (b) The disputed domain name consists of a misspelling (typosquatting) of the Complainant's well-known mark, with no conceivable good faith use; (c) The Respondent's initial use of the disputed domain name was to host pay-per-click links to the Complainant's competitors, demonstrating a pattern of bad faith exploitation. In the circumstances of this case, the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The totality of the circumstances demonstrates that the disputed domain name was registered and is being used in bad faith. The Panel finds that the Complainant has established the third element of the Policy. page 6 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 <sdexo.website> be transferred to the Complainant. /Pascal Böhner/ Pascal Böhner Sole Panelist Date: October 24, 2025

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

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