Westmore · UDRP decision
WIPO · Case No. D2025-5252

Sodexolivefl.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <sodexolivefl.com>. It found the domain confusingly similar to the SODEXO LIVE! mark because it reproduced the mark apart from the exclamation mark and added only “fl” and the “.com” generic Top-Level Domain. The Complainant established a prima facie case that the Respondent lacked rights or legitimate interests, which the defaulting Respondent did not rebut. Bad faith was found based on the reputation and distinctiveness of the Complainant’s marks, their incorporation into the domain, the substantial priority of the trademark registrations, the absence of any good-faith explanation, the inherently misleading composition of the domain, and passive holding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-09
Panelist(s)
Nanobashvili, Levan
Complainant
SODEXO
Respondent
Jose Delcid
Counsel
Areopage
Disputed domain(s)
sodexolivefl.com
Citation weightrelies on 6 authorities
Domain history UDRP Intelligence

The timeline behind sodexolivefl.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 sodexolivefl.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 sodexolivefl.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain that combines a recognizable mark with an unexplained short term can satisfy all three UDRP elements even without active website use. The result rested not merely on default, but on documented prior rights, recognition of the mark within the domain, an unrebutted prima facie case, mark reputation, the domain’s misleading composition, and passive holding.

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
2026-02-09
Panel
Nanobashvili, Levan
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION SODEXO v. Jose Delcid Case No. D2025-5252 1. The Parties The Complainant is SODEXO, France, represented by Areopage, France. The Respondent is Jose Delcid, Honduras. 2. The Domain Name and Registrar The disputed domain name <sodexolivefl.com> is registered with LiquidNet Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 16, 2025. On December 17, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 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 (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 18, 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 18, 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 December 22, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 22, 2026. page 2 The Center appointed Levan Nanobashvili as the sole panelist in this matter on January 26, 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 (formerly SODEXHO ALLIANCE), is a French company established in 1966. The Complainant specializes in food services and facilities management on a global scale. With a workforce of more than 426,000 employees, the Complainant is one of the largest employers in the world, serving 80 million consumers daily across 43 countries. In the 2025 fiscal year, the Complainant’s consolidated revenues reached EUR 24.1 billion. From 1966 to 2008, the Complainant conducted its business under SODEXHO mark. Since 2008, the Complainant has changed the mark to SODEXO. The Complainant owns numerous trademarks worldwide for SODEXO, SODEXHO, and SODEXO LIVE!, including the following: 1) International Trademark SODEXO (figurative), registration No. 964615, registered on January 8, 2008, duly renewed, International Classes 9, 16, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45, designating multiple jurisdictions; 2) International Trademark SODEXHO (figurative), registration No. 689106, registered on January 28, 1998, duly renewed, International Classes 16, 36, 37, 39, 41, and 42, designating multiple jurisdictions; and 3) International Trademark SODEXO LIVE! (figurative), registration No. 1648068, registered on October 15, 2021, International Classes 35, 39, 41, 43, and 45, designating multiple jurisdictions. The Complainant holds various domain names incorporating SODEXO and SODEXHO marks, including <sodexo.com>, <sodexho.com>, <sodexo.fr>, and <sodexho.fr>. The disputed domain name was registered on December 12, 2025. At the time the Complaint was filed, the disputed domain name resolved to a hosting provider parked page. At the time of the Decision, the disputed domain name still does not resolve to an active website. The Respondent, Jose Delcid, is an individual reportedly residing in Honduras. 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: (i) the SODEXO and SODEXHO marks enjoy a strong reputation and are widely recognized on a global scale; (ii) the disputed domain name is confusingly similar to the SODEXO and the SODEXO LIVE! marks in which the Complainant has rights; page 3 (iii) the Respondent has no rights or legitimate interests in the disputed domain name; (iv) the Respondent has no affiliation or connection with the Complainant and has never been authorized or licensed to register the disputed domain name or use it; (v) the SODEXO mark is fanciful and nobody could legitimately have chosen this word or any variation, unless seeking to create an association with the Complainant; (vi) the SODEXO mark is well known and, therefore, the Respondent knew about its existence when he registered the disputed domain name. The Respondent registered the disputed domain name intending to exploit the mark’s reputation; (vii) the Respondent registered the disputed domain name with actual knowledge of the Complainant’s rights in the SODEXO mark, intending to create consumer confusion and to divert or mislead third parties for commercial gain; and (viii) a passive holding of the disputed domain name does not prevent a finding of bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving that: (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 Respondent’s default in the case at hand does not automatically result in a decision in favor of the Complainant. However, paragraph 5(f) of the Rules provides that if the Respondent does not submit a response, in the absence of exceptional circumstances, the Panel shall decide the dispute based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel shall draw such inferences from the Respondent’s failure to submit a response as it considers appropriate. 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 SODEXO LIVE! mark save for the exclamation 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. page 4 Although the addition of other terms, here “fl”, may bear on assessment of the second and third elements, the Panel finds the addition of such a term 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 addition of the generic Top-Level Domain “.com” is a standard registration requirement and, as such, is disregarded under the first element confusing similarity test. WIPO Overview 3.0, section 1.11.1. 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. Specifically, the Respondent provided no evidence that it has used or made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods of services, has been commonly known by the disputed domain name, or has made a legitimate noncommercial use thereof. The Respondent has not rebutted the Complainant’s contention that it has not authorized the Respondent to use its marks, or that there is no relationship between them that would justify the Respondent’s registration and use of the Complainant’s marks in the disputed domain name. 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. 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 consistently found that the mere registration of a domain name that is confusingly similar (particularly domain names incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4. page 5 A significant number of panels have consistently found that the Complainant’s SODEXO mark is widely known. (Sodexo v. Italo Trentino, WIPO Case No. D2025-3714, SODEXO v. Lowell Clark, WIPO Case No. D2024-2377, Sodexo v. Sebastian Barra Alarcon, Sodexo, WIPO Case No. D2024-0501, Sodexo v. Daniela Ortiz, WIPO Case No. D2021-0628, and SODEXO v. Ashutosh Dwivedi, Food & Beverages, WIPO Case No. D2020-2686). The Panel finds it unlikely that the Respondent was unaware of the Complainant’s SODEXO and SODEXO LIVE! marks when registering the disputed domain name, noting that both are incorporated therein. Given this prior knowledge, and in accordance with section 3.1.4 of the WIPO Overview 3.0, the Panel concludes that the Respondent's incorporation of the Complainant’s mark in the disputed domain name, for which no explanation was provided, creates a presumption of bad faith in the circumstances of this case. The Panel finds that the Complainant’s trademark registrations significantly predate the registration date of the disputed domain name. A significant gap between registration of the Complainant’s trademarks and the Respondent’s registration of the disputed domain name containing the trademarks at issue can indicate the bad faith registration (Hi-TEC Sports International Holdings B.V. v. Thomas Birch, Finlay Nolan, Anna Akhtar, Tyler Reynolds, Keira Donnelly, WIPO Case No. D2024-1891). The Panel notes that the Respondent has provided no evidence demonstrating any good faith intention behind the registration of the disputed domain name 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. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademarks, the composition of the inherently misleading 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. 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 <sodexolivefl.com> be transferred to the Complainant. /Levan Nanobashvili/ Levan Nanobashvili Sole Panelist Date: February 9, 2026

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

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