Westmore · UDRP DecisionSodesxo.com
The Panel ordered transfer of <sodesxo.com> to SODEXO. It found the domain confusingly similar because it reproduces the SODEXO mark with an additional letter “s”; found that the Complainant’s prima facie case on rights or legitimate interests was unrebutted; and found bad-faith registration and use based on the apparent targeting of the mark, the absence of a credible explanation, and passive holding under circumstances making good-faith use implausible.
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The decision illustrates a straightforward single-letter insertion typosquatting pattern combined with passive holding. The Panel did not require proof of an operational scam: the recognizable misspelling, inferred targeting, absence of a credible explanation, and circumstances making good-faith use implausible were sufficient to establish bad faith.
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 SODEXO v. IT RENEW Case No. D2025-4756 1. The Parties The Complainant is SODEXO, France, represented by Areopage, France. The Respondent is IT RENEW, United States of America. 2. The Domain Name and Registrar The disputed domain name <sodesxo.com> is registered with Squarespace Domains LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 17, 2025. On the same day, the Center sent an email to the Registrar requesting information in connection with the disputed domain name. On November 17, 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 (REDACTED FOR PRIVACY / Unknown, Oklahoma) and contact information provided in the Complaint. On November 19, 2025, The Center sent an email to the Complainant, 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 November 20, 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 November 25, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 15, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 17, 2025. The Center appointed Simone Lahorgue Nunes as the sole panelist in this matter on December 22, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant, founded in 1966, is headquartered in France. The company is “one of the largest companies in the world specialized in food services and facilities management” and operates with “426,000 employees serving daily 80 million consumers in 43 countries”. The Complainant promoted its business under the “SODEXHO” mark and trade name from 1966 to 2008. In 2008, SODEXHO changed its name to “SODEXO”. The Complainant has provided evidence of being the right holder of the trademark SODEXO, for instance: - International Trademark registration No 964615, registered on January 8, 2008; - International Trademark registration No 1240316, registered on October 23, 2014; - European Union Trademark registration No 008346462, registered on February 1, 2010. The Complainant has also provided evidence of being the right holder of the trademark SODEXHO, for instance: - International Trademark registration No 689106, registered on January 28, 1998; - International Trademark registration No 694302, registered on June 22, 1998; Furthermore, the Complainant asserts that it is the owner of the domain name <sodexo.com>, registered on October 9, 1998. The disputed domain name was registered by the Respondent on November 13, 2025. The website results to an “under construction” webpage and is still active. The Respondent did not reply to the Complainant’s contentions. 5. Parties’ Contentions A. Complainant The Complainant claims that the disputed domain name is “identical or confusingly similar” to the Complainant’s trademarks SODEXO and SODEXHO. The Complainant argues that it owns numerous domain names corresponding to and/or containing SODEXO or SODEXHO and that the “SODEXO / SODEXHO mark is continuously and extensively used and registered worldwide”. In addition, the Complainant claims that “the company SODEXO is widely established and among others in the United States of America where the Respondent is located”. The Complainant contends that in earlier cases, the Center has already “recognized the well-known character of the SODEXO / SODEXHO mark” (see e.g., Sodexo v. Registration Private, Domains By Proxy, LLC / Carolina Rodrigues, Fundacion Comercio Electronico, WIPO Case No. D2020-1580; Sodexo v. Contact Privacy Inc. Customer 1247189803 / NorAm Accounts Receivable, WIPO Case No. D2020-1683). The Complainant contends that the disputed domain name <sodesxo.com> “incorporates the SODEXO mark almost identically, with the addition of the letter S between the letter E and the letter X” and that “this additional letter is melted in the sign and will not attract the consumer’s attention”. The Complainant notes that there is “an obvious misspelling of the SODEXO mark which can be made by an Internet user” and that this “is characteristic of typosquatting practice intended to create confusing similarity between the Complainant's mark and Respondent's domain name”. page 3 The Complainant shows several cases in which the Panel found that the domain name was confusingly similar to the Complainant’s trademark (see e.g. SODEXO v. 蒋红群 (hongqun jiang), WIPO Case No. D2022-3927; Sodexo v. Registration Private, Domains By Proxy, LLC / Name Redacted, WIPO Case No. D2021-3082). The Complainant alleges that it has recently been the target of several attacks and has serious concerns that the disputed domain name <sodesxo.com> may be used for fraudulent purposes, particularly to carry out email scams directed at its clients, including requests for payment of false invoices to fake Sodexo bank accounts “or to order products to Complainant’s clients for considerable amounts by impersonating Complainant’s employee”. Furthermore, the Complainant argues that the Respondent has no rights nor legitimate interests in the disputed domain name “as it has no rights on SODEXO as corporate name, trade name, shop sign, mark or domain name that would be prior to the Complainant’s rights on SODEXO”. In addition, the Complainant argues that the disputed domain name <sodesxo.com> was registered and is being used in bad faith. According to the Complainant “it is obvious that the Respondent registered the domain name sodesxo.com with actual knowledge of Complainant's rights in the SODEXO mark very likely for the purpose of creating confusion with Complainant's mark to divert or mislead third parties for Respondent's illegitimate profit”. Finally, the Complainant asserts that “even if the disputed domain name, which has been recently created, does not currently appear to point to a website with active content, a passive holding of a domain name does not prevent a finding of bad faith”. Therefore, the Complainant requests the transfer of the disputed domain name to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The analysis of the Complainant’s arguments and of the presented evidence leads to the conclusion that the Complaint should be upheld, based on the following grounds: 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 Panel finds the mark is 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 disputed domain name incorporates a misspelling of the Complainant’s mark, namely adding an extra “s” letter. The Panel finds such letter 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 1.9. page 4 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 relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. 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 Respondent’s bad faith registration and use of the disputed domain name for the following reasons: First, the use of the SODEXO trademark in the disputed domain name with the addition of the letter “s”, suggests that the Respondent has registered the disputed domain name with the actual knowledge of the Complainant and its trademarks, and has done so in an attempt to create a likelihood of confusion with the Complainant. Second, it is clear that the Respondent lacks rights or legitimate interests in the disputed domain name and this is reinforced by the fact that there is no credible explanation for the Respondent’s choice of the disputed domain name as the Respondent did not reply to the Complainant’s contentions. WIPO Overview 3.0, section 3.2.1. 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 or reputation of the Complainant’s trademark, the implausibility of any good faith use to which the disputed domain name may be put, and the composition of the disputed domain name including a misspelling of the Complainant’s trademark, 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 Policy. 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 <sodesxo.com> be transferred to the Complainant. /Simone Lahorgue Nunes/ Simone Lahorgue Nunes Sole Panelist Date: January 5, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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