Westmore · UDRP decision
WIPO · Case No. D2026-0538

Carefourr.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <carefourr.com>. It found the domain confusingly similar to the CARREFOUR trademarks because it was an intentional misspelling in which the second “r” was moved to the end. The Complainant established a prima facie case that the Respondent lacked rights or legitimate interests, which the non-responding Respondent did not rebut. Bad faith was established from the longstanding and well-known CARREFOUR marks, the domain’s typosquatting composition, and passive holding under the totality of the circumstances.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-09
Panelist(s)
Meijboom, Alfred
Complainant
Carrefour SA
Respondent
Steelcone Martin Ullenbrauck
Counsel
IP Twins
Disputed domain(s)
carefourr.com
Domain history UDRP Intelligence

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

This decision illustrates a conventional typosquatting and passive-holding pattern involving a well-known mark. A minor rearrangement rather than the addition or deletion of a character did not avoid confusing similarity. For bad faith, the Panel relied on the mark’s longstanding reputation, the obvious typo composition, and passive holding, without needing a finding of actual phishing or active website use.

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
2026-04-09
Panel
Meijboom, Alfred
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Carrefour SA v. Steelcone Martin Ullenbrauck Case No. D2026-0538 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondent is Steelcone Martin Ullenbrauck, United States of America. 2. The Domain Name and Registrar The disputed domain name <carefourr.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 February 9, 2026. On February 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 10, 2026, 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 February 11, 2026, 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 February 13, 2026. The Center verified that the Complaint together with 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 February 18, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 10, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 19, 2026. The Center appointed Alfred Meijboom as the sole panelist in this matter on March 26, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration page 2 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 with a turnover of EUR 87.2 billion in 2024, which operates more than 14,000 stores in more than 40 countries worldwide, employing over 500,000 employees worldwide and millions of daily unique visitors in its stores. In addition, the Complainant offers travel, banking, insurance, and ticketing services. The Complainant owns several hundred trademark registrations worldwide for the term CARREFOUR, including: • International trademark registration with no. 351147 for the word mark CARREFOUR, registered on October 2, 1968, for goods in classes 1 to 34; and • International trademark registration with no. 353849 for the word mark CARREFOUR, registered on February 28, 1969, for services in classes 35 to 42. The Complainant is also owner of domain names which include the CARREFOUR trademark, including <carrefour.com> which was created in 1995. The disputed domain name was registered on January 30, 2026. The disputed domain name is inactive and directs to a website displaying the message “The content of the page cannot be displayed“. 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 the disputed domain name is confusingly similar to the Complainant’s CARREFOUR trademarks because said trademarks are well-known and immediately recognizable in the disputed domain name, despite the minor misspelling of a letter “r” having been moved from its original position and appending at the end of the disputed domain name. Further, the Complainant alleges that the Respondent has no rights or legitimate interests in respect of the disputed domain name because the Respondent is not known by the disputed domain name, has not acquired rights in a corresponding trademark, was not licensed or authorized by the Complainant to register and use the disputed domain name, and the Respondent did not use the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services, nor did it make any serious preparations to do so. The Complainant also alleges that the specific composition of the disputed domain name can only be reasonably understood as a misspelling of the Complainant’s CARREFOUR trademarks and suggests the Respondent’s intention to take unfair advantage of the likelihood of confusion between the disputed domain name and the Complainant, which is, according to the Complainant, supported by a warning given in case of a specific search on Google for the email address “[...]@carefourr.com” which suggests “a potential typo in the domain (..) or a phishing attempt”. The Complainant further contends that the Respondent has registered and is using the disputed domain name in bad faith. According to the Complainant, the Respondent has registered the disputed domain name in bad faith because the Complainant’s CARREFOUR trademarks, which were registered significantly prior to the registration of the disputed domain name, are so widely known that it is inconceivable that the Respondent was not aware of the Complainant’s earlier rights in its CARREFOUR trademarks. Moreover, the Complainant alleges that the Respondent is also using the disputed domain name in bad faith as it does page 3 not resolve to an active website, which non-use of the disputed domain name does not prevent a finding of bad faith under the doctrine of passive holding. The Complainant also claims that the disputed domain name is technically capable of being used for sending emails which, in view of its confusing similarity to the Complainant’s official <carrefour.com> domain name, significantly increases the risk that Internet users receiving emails from the disputed domain name may be misled, as well as the disputed domain name potentially being used for abusive activities, such as phishing. Given the Complainant’s long-lasting international relationship with its CARREFOUR trademarks, the Complainant cannot think of any future use of the disputed domain name that may be done by the Respondent in good faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The Respondent did not file a Response. However, as set out in section 4.3 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), the consensus view of UDRP panels is that the respondent’s default does not automatically result in a decision in favor of the Complainant. The Complainant must still establish each of the three elements required by paragraph 4(a) of the Policy. Although the Panel may draw appropriate inferences from the Respondent’s default, paragraph 4 of the Policy requires the Complainant to support its assertions with actual evidence in order to succeed in this proceeding. Paragraph 14(b) of the Rules provides that, in the absence of exceptional circumstances, the panel shall draw such inferences as it considers appropriate from a failure of a party to comply with a provision or requirement of the Rules. The Panel finds that in this case there are no such exceptional circumstances. Under the Policy, the Complainant must prove that: (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 3.1, section 1.7. The Panel finds that the CARREFOUR trademark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the Complainant’s CARREFOUR trademarks for the purposes of the Policy (WIPO Overview 3.1, section 1.7). The Panel is satisfied that the disputed domain name consists of an intentional misspelling of the Complainant’s CARREFOUR trademarks, as the second “r” in CARREFOUR has been placed after the last “r.” Based on the available record, 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 that a respondent lacks rights or legitimate interests in a domain name may result in the difficult page 4 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 3.1, 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 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 present matter, the CARREFOUR trademarks were registered more than five decades before the Respondent registered the disputed domain name. The Panel is satisfied that the CARREFOUR trademarks have been used extensively and are therefore well known, as can be inferred from the undisputed use of the CARREFOUR trademarks by the Complainant for its goods and services in many countries worldwide, such that millions of people come into contact with these trademarks on a daily basis. This reputation of the CARREFOUR trademarks has also been confirmed in many previous panel decisions, referred to by the Complainant. According to WIPO Overview 3.1, section 3.1.4, panels “have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos [...]) to a well-known trademark, and particularly in the case of coined or fanciful marks, can by itself create a presumption of bad faith.” The Panel is therefore satisfied that the Respondent registered the disputed domain name in bad faith. Further, previous panels have found that the non-use of a domain name would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the reputation of the Complainant’s trademarks, and the composition of the disputed domain name, which seem to be nothing less than the result of straightforward typosquatting, 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 also 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 <carefourr.com> be transferred to the Complainant. /Alfred Meijboom/ Alfred Meijboom Sole Panelist Date: April 9, 2026

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

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