Westmore · UDRP decision
WIPO · Case No. D2025-4185

Carrefour-sas.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <carrefour-sas.com>. It found the domain confusingly similar to the Complainant’s CARREFOUR mark because it reproduced the mark in its entirety and the addition of “sas” did not prevent confusing similarity. The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests, and the domain’s composition carried a risk of implied affiliation. Considering the mark’s reputation, the domain’s composition, the lack of a response, and the passive holding of the domain, the Panel also found registration and use in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-12-03
Panelist(s)
Tayer, David-Irving
Complainant
Carrefour SA
Respondent
pascaline ledema
Counsel
IP Twins
Disputed domain(s)
carrefour-sas.com
Domain history UDRP Intelligence

The timeline behind carrefour-sas.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 carrefour-sas.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 carrefour-sas.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining a well-known trademark with a corporate-form abbreviation can support both implied-affiliation and bad-faith findings, even when the domain is not actively used. The result rested on the cumulative circumstances identified by the Panel rather than on an active impersonation or commercial website.

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
2025-12-03
Panel
Tayer, David-Irving
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Carrefour SA v. pascaline ledema Case No. D2025-4185 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondent is pascaline ledema, France. 2. The Domain Name and Registrar The disputed domain name <carrefour-sas.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 13, 2025. On October 13, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 13, 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 (User #0c694dfd Privacy, PrivacyGuardian.org llc) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 14, 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 October 14, 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 October 24, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 13, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 14, 2025. page 2 The Center appointed David-Irving Tayer as the sole panelist in this matter on November 19, 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 worldwide leader in retail and a pioneer of the concept of hypermarkets back in 1968. With a turnaround of 76 billion euros in 2018, 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. The Complainant presents itself as a major and well-known worldwide leader in retail. The Complainant additionally offers travel, banking, insurance, or ticketing services. The Complainant owns hundreds of trademark rights worldwide and in particular, - European Union Trade Mark CARREFOUR No. 008779498, registered on July 13, 2010, duly renewed, and designating goods in international class 35; - International trademark CARREFOUR No. 563304, registered on November 6, 1990, duly renewed, and designating goods and services in international class 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, claiming a protection notably in Algeria, Armenia, Benelux Egypt, Greece, Israel, Singapore, Switzerland, Germany, Portugal, Romania, Russian Federation, Slovakia, Slovenia; - French trademark CARREFOUR No. 1565338, registered on May 25,1990, duly renewed, and designating goods in international class 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34; and - United States of America trademark CARREFOUR No. 6763415, registered on June 21, 2022, duly renewed, and designating goods in international class 35. The Complainant also owns numerous domain names integrating “CARREFOUR” and that are used such as: - <carrefour.com> registered since at least October 25, 1995; and - <carrefour.fr> registered at least since June 23, 2005. The Complainant added that its Facebook page is currently “liked” by more than 11 million Internet users and almost 6.2 million Internet users “like” the CARREFOUR TikTok account and more than 740 thousand followers on the CARREFOUR Instagram account. The disputed domain name was registered on September 15, 2025. The disputed domain name is inactive but for the presence of the hosting landing page. 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 each of the three elements specified in paragraph 4(a) of the Policy are satisfied in the present case. page 3 Firstly, the Complainant submits that the disputed domain name is identical or confusingly similar to the trademark registrations of the Complainant. Secondly, the Complainant argues that the Respondent has neither rights nor legitimate interests in the disputed domain name. Thirdly, the Complainant submits that the disputed domain name was registered and is being used in bad faith. In particular, the Complainant asserts that the disputed domain name leads to an inaccessible website. Furthermore, the Complainant indicates that the Respondent could not ignore the repute of the Complainant’s trademarks. B. Respondent The Respondent did not reply to the Complainant’s contentions 6. Discussion and Findings Paragraph 4(a) of the Policy provides that a complainant must prove each of the following elements with respect to a disputed domain name: (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. The Respondent’s default does not by itself mean that the Complainant is deemed to have prevailed. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.3. 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 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 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, “sas” after the Complainant’s trademarks and separated by an hyphen, may bear on assessment of the second and third elements, the Panel finds the addition of such term, meaning “Société par Actions Simplifiée” (one of the French legal nature of a company and commonly used) 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. page 4 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 relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Respondent has not, before the original filing of the Complaint, used or made preparations to use the disputed domain name in relation to a bona fide offering of goods or services for presenting a simple webpage of the registrar. Moreover, the composition of the disputed domain name, incorporating the Complainant’s well-known trademark with “sas”, carries 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. 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 is a well-known company as a worldwide leader in retail and a pioneer of the concept of hypermarkets and that it has long been operating in the market; - the disputed domain name was registered on September 15, 2025; and - the disputed domain name does not resolve to an active webpage. 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. WIPO Overview 3.0, section 3.2.1. Panels have found that the non-use of a domain name (including a blank or hosting landing 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 reputation of the Complainant’s trademark, the composition of the disputed domain name, and the lack of response, 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. page 5 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 <carrefour-sas.com> be transferred to the Complainant. /David-Irving Tayer/ David-Irving Tayer Sole Panelist Date: December 3, 2025

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

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