Westmore · UDRP decision
WIPO · Case No. D2025-4911

Sodexxo.net

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <sodexxo.net> to Sodexo. It found the domain confusingly similar to the SODEXO mark because it reproduced the mark with one additional letter “x”; found no rights or legitimate interests because the Respondent was not authorized or commonly known by the domain and presented no evidence of legitimate use; and found bad-faith registration and use based on the mark’s reputation and distinctiveness, the typographical misspelling, the Respondent’s lack of a substantive response, and passive holding of the inactive domain.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-13
Panelist(s)
Kraus, Daniel
Complainant
Sodexo
Respondent
Tim Warburton
Counsel
Areopage
Disputed domain(s)
sodexxo.net
Citation weightrelies on 3 authorities
Domain history UDRP Intelligence

The timeline behind sodexxo.net

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

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

This decision illustrates the intersection of straightforward single-letter typosquatting, passive holding, and apparent identity theft. The Panel did not require proof of active website misuse because the mark’s reputation and distinctiveness, the targeted misspelling, the lack of legitimate explanation, and the absence of substantive participation collectively supported bad faith. It also demonstrates careful treatment of registrar-disclosed personal information where the named individual may be an identity-theft victim.

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
2026-01-13
Panel
Kraus, Daniel
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sodexo v. Name Redacted Case No. D2025-4911 1. The Parties The Complainant is Sodexo, France, represented by Areopage, France. The Respondent is Name Redacted 1 . 2. The Domain Name and Registrar The disputed domain name <sodexxo.net> the (“Disputed Domain Name”) is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 25, 2025. On November 26, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On December 1, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 2, 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 December 4, 2025. 1 The underlying registrant of the Disputed Domain Name appears to have used the name and contact details of a third party when registering the Disputed Domain Name. In light of the potential identity theft, the Panel has redacted the name of this registrant from this Decision. However, the Panel has attached as Annex 1 to this Decision an instruction to the concerned Registrar regarding transfer of the Disputed Domain Name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the concerned Registrar as part of the order in these proceedings, and has indicated that Annex 1 to this Decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. 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 Respondent of the Complaint, and the proceedings commenced on December 8, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 28, 2025. The Respondent sent an email communication to the Center on December 11, 2025. Accordingly, the Center notified the Parties of the commencement of panel appointment process on December 29, 2025. The Center appointed Daniel Kraus as the sole panelist in this matter on January 6, 2026. 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, Sodexo (previously called Sodexho Alliance), is a French company founded in 1966. It is one of the world’s largest providers of food services and facility management solutions. The Complainant employs more than 426,000 people and serves 80 million consumers every day across 43 different countries. From 1996 to 2008, it operated under the trademark and business name SODEXHO. In 2008, the company rebranded and simplified its name to SODEXO. The Complainant is the owner of numerous trademarks consisting of or containing the word “Sodexo”, such as: - European Union Trade Mark Registration SODEXO No. 008346462, registered on February 1, 2010, for goods and services in classes 9, 16, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45; and - European Union Trade Mark Registration SODEXO (figurative trademark) No. 006104657, registered on June 27, 2008, for goods and services in classes 9, 16, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45. In addition, several prior UDRP decisions have recognized that the Complainant’s trademarks are well known, including Sodexo v. Contact Privacy Inc. Customer 1247189803 / NorAm Accounts Receivable, WIPO Case No. D2020-1683, and SODEXO v. Super Privacy Service LTD c/o Dynadot / Zhichao, WIPO Case No. D2020-1762. The Complainant is also the owner of domain names such as <sodexo.com>. The Disputed Domain Name was registered on November 20, 2025 and is currently inactive. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the conditions required under the Policy for a transfer of the Disputed Domain Name. Notably, the Complainant contends that: - The Disputed Domain Name is confusingly similar to its well-known SODEXO trademark in its entirety, with the mere addition of the letter “x” after the existing “x”, which does not prevent a finding of confusing similarity. page 3 The minor typographical variation does not materially alter the visual or phonetic impression of the SODEXO mark. - The Complainant emphasizes that it is widely established in various countries and that the SODEXO and SODEXHO trademarks are globally recognized and enjoy a strong reputation. - The Respondent has no rights or legitimate interests in the Disputed Domain Name. In particular, the Complainant states that it has never authorized, licensed, or otherwise permitted the Respondent to use the SODEXO trademark in any form, nor is the Respondent commonly known by the Disputed Domain Name. - The Respondent registered and is using the Disputed Domain Name in bad faith. The Complainant argues that given the global recognition of the SODEXO brand, the Respondent could not have been unaware of the Complainant’s well-known trademarks at the time of registration. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. However, on December 11, 2025, the Respondent sent an email communication to the Center, indicating that he has nothing to do with the Disputed Domain Name. 6. Discussion and Findings Paragraph 4(a) of the Policy provides that the Complainant proves each of the following three elements in order to succeed in its Complaint: (i) the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (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. 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 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. The Panel finds the addition of the letter “x” does not prevent a finding of confusing similarity between the Disputed Domain Name and the SODEXO trademarks for the purposes of the Policy. WIPO Overview 3.0, section 1.9. 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. There is no evidence that the Respondent is commonly known under the Disputed Domain Name. The Respondent has not been licensed or otherwise authorized by the Complainant to use its SODEXO trademarks in any manner. Furthermore, the Disputed Domain Name resolves to an inactive page, and there is no indication that the Respondent is using, or has made any demonstrable preparations to use, the Disputed Domain Name in connection with a legitimate noncommercial or fair use purpose. 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 given the strong reputation and long-standing use of the Complainant’s SODEXO trademarks, it is unlikely that the Respondent was unaware of the Complainant’s trademarks at the time of registration. The Panel observes that (i) the Complainant’s trademark registrations predate the registration of the Disputed Domain Name by many years; (ii) the SODEXO trademarks are distinctive and have no descriptive meaning; (iii) the Disputed Domain Name does not resolve to any active website, but rather to an inactive page; (iv) the Disputed Domain Name consisting of a misspelling of the Complainant’s mark signals an awareness of the Complainant; and (v) the Respondent has failed to provide any evidence of actual or contemplated good faith use of the Disputed Domain Name, having also failed to respond substantively to the Complaint. These circumstances strongly suggest that the Respondent was aware of and deliberately targeted the Complainant’s trademarks, when registering the Disputed Domain Name. The Respondent’s conduct indicates an intention to confuse Internet users seeking or expecting the Complainant, which constitutes bad faith registration and use under paragraph 4(a)(iii) of the Policy. 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, 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 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 <sodexxo.net> be transferred to the Complainant. /Daniel Kraus/ Daniel Kraus Sole Panelist Date: January 13, 2026

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

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