Westmore · UDRP DecisionCarefour.sale
The Panel ordered transfer of <carefour.sale> after finding all three UDRP elements established. The domain omitted one letter “r” from the CARREFOUR mark and resolved to an Arabic-language website presenting an apparent “Carrefour Ramadan Prize Campaign” offering USD 500 and leading users to a form requesting personal information. The Panel found confusing similarity, no rights or legitimate interests, intentional confusion under paragraph 4(b)(iv), and an obvious and significant concern of phishing or other fraudulent data collection practices.
The timeline behind carefour.sale
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 carefour.sale — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a simple omitted-letter typo, when combined with a website impersonating the trademark owner and collecting personal data, can provide a cohesive evidentiary basis across all three UDRP elements. The Panel relied not only on the domain’s similarity but also on the website’s exact use of the CARREFOUR mark, purported prize promotion, and progressive data-collection flow.
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 Carrefour SA v. Whois Agent, Netlify Inc Case No. D2026-0944 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondent is Whois Agent, Netlify Inc, United States of America. 2. The Domain Name and Registrar The disputed domain name <carefour.sale> is registered with Name.com, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 5, 2026. On March 5, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 5, 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 (The RDAP server redacted the value) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 10, 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 March 12, 2026. 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 March 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 6, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 10, 2026. The Center appointed Alistair Payne as the sole panelist in this matter on April 20, 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. page 2 4. Factual Background The Complainant is a significant international retailer based in France. It developed the hypermarket concept in 1963 and is publicly listed on the Paris Stock Exchange. According to the Complainant, the Complainant has more than 384,000 employees worldwide, 1.3 million daily visitors in its webstores and annual revenues in the tens of billions of Euros. The Complainant owns numerous trade mark registrations worldwide for its CARREFOUR mark, including International trade mark No. 351147 for CARREFOUR registered on October 2, 1968 which is designated in several jurisdictions and the European Union trade mark registration 005178371 registered on August 30, 2007. The Complainant owns numerous domain names incorporating its CARREFOUR mark including <carrefour.com> which was registered in 1995 from which it operates its main website and <carrefour.net> which was registered in 2001. The Complainant’s CARREFOUR mark and business have a very considerable social media presence. The disputed domain name was registered on February 24, 2026 and at the time of filing it resolved to a website displaying content written in Arabic. When accessing the homepage, a pop-up window immediately appears in the centre of the screen, preventing direct access to the underlying content of the page. The background of the homepage is blurred and therefore not fully visible. However, the visible elements of the background include a colour scheme combining red and blue, which corresponds to the colours commonly used by the Complainant in connection with its CARREFOUR brand. The pop-up window contains several lines of text written in Arabic script. The CARREFOUR mark appears within the text in Latin characters with two “r”, corresponding to the spelling of the Complainant’s trade mark, whereas the disputed domain name itself contains only one “r”. The pop-up also contains a gift icon and a coloured box prominently displaying the number “500”, referring to a purported cash prize. A button displayed at the bottom of the pop-up invites users to participate in the campaign. When the user clicks this button, the website redirects the user to a second page. This page displays several rectangular boxes arranged in rows, each containing short statements presented as comments from alleged participants in the campaign. Above the page there appears the legend in English as a reference: “ Carrefour Ramadan Prize Campaign”. At the bottom of the page, a green button accompanied by an arrow invites the user to continue the process. By clicking this button, the user is redirected to another page displaying a form requesting personal information. The form contains several fields which according to the Complainant’s translation, request, inter alia, the user’s full name, age, mobile phone number, and place of residence, as well as a field inviting the user to rate the services of “Carrefour”. The form also appears to contain validation messages indicating that certain fields are required before submission. A blue button appears at the bottom of the form inviting the user to continue the process. 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 it owns registered trade mark rights for its CARREFOUR mark as noted above. It says that the disputed domain name reproduces the Complainant’s CARREFOUR trade mark in a nearly identical form and that the only difference consists of the omission of one of the two letters “r” appearing in the Complainant’s mark. Such a minor typographical alteration does not prevent a finding of confusing similarity under the Policy according to the Complainant. As noted in section 1.9 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”) , a domain name which consists of a common, obvious, or intentional misspelling of a trade mark is considered confusingly similar to the relevant mark for purposes of the first element of the Policy. page 3 The Complainant says that the omission of a single letter from the Complainant’s trade mark constitutes a typical example of such “typosquatting”. The disputed domain name therefore retains the overall visual and phonetic impression of the Complainant’s CARREFOUR trade mark and remains clearly recognisable within the disputed domain name. The Complainant submits that there is no evidence that the Respondent is commonly known by the disputed domain name, or that it has authorised, licensed, or otherwise permitted the Respondent to use the CARREFOUR trade mark in any manner, including to register or use any domain name incorporating the CARREFOUR trade mark or a variation thereof. The Complainant says that the Respondent is not affiliated with the Complainant, and there is no relationship between the Parties that could give rise to any right or legitimate interest in the disputed domain name. The Complainant also says that the Respondent is not using the disputed domain name in connection with any bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy. It asserts that the disputed domain name resolves to a website presenting what appears to be a promotional campaign using the wording “Carrefour” and inviting users to participate in a prize campaign purportedly offering a cash reward. The website guides users through several steps to a form requesting personal information, including the user’s name, age, telephone number, and place of residence. The Complainant submits that, as noted in section 2.13 of the WIPO Overview 3.1, the use of a domain name for illegal activity, including phishing or other fraudulent schemes, can never confer rights or legitimate interests on a respondent. Finally, says the Complainant, the Respondent is not making any legitimate noncommercial or fair use of the disputed domain name within the meaning of paragraph 4(c)(iii) of the Policy. According to the Complainant, the disputed domain name consists of a misspelling of the Complainant’s distinctive trade mark, and the associated website displays the wording “Carrefour” in Latin characters, thereby suggesting an association with the Complainant which does not exist and taking unfair advantage of its mark in a manner that cannot amount to legitimate noncommercial or fair use under the Policy. As far as registration in bad faith is concerned, the Complainant says that at the date of registration of the disputed domain name, the Complainant’s CARREFOUR trade mark had long been widely known and extensively used in connection with the Complainant’s retail activities in numerous jurisdictions around the world. Considering the distinctiveness and reputation of the CARREFOUR trade mark, it is inconceivable, says the Complainant, that the Respondent registered the disputed domain name without knowledge of the Complainant and its trade mark rights. The Complainant notes that panels have consistently found that the registration of a domain name incorporating a well-known trade mark by an unaffiliated party strongly supports a finding of bad faith. The disputed domain name constitutes a clear misspelling of the Complainant’s CARREFOUR trade mark, consisting of the omission of one of the two letters “r” in the mark. This typographical alteration is characteristic of typosquatting. The Complainant submits that in the present case, the disputed domain name preserves the overall visual and phonetic impression of the CARREFOUR trade mark and clearly targets the Complainant’s mark. Finally as to registration in bad faith, the Complainant says that by combining a misspelling of the CARREFOUR trade mark with a Top-Level Domain referring to commercial sales, the Respondent has created a domain name that reinforces the likelihood that Internet users will associate the disputed domain name with the Complainant and that this all points to registration of the disputed domain name in bad faith. The Complainant submits that, as described above, the disputed domain name is being used in bad faith. It says that the website displays the wording “Carrefour” written in Latin characters, using the exact spelling of the Complainant’s trade mark with two “r”s despite the disputed domain name itself containing only one “r”. The website also uses a red and blue colour scheme corresponding to the colours commonly used by the Complainant in connection with its CARREFOUR brand. It notes that the website invites Internet users to participate in what is presented as a promotional campaign allegedly organized by “Carrefour”, offering participants the opportunity to win a cash prize of USD 500. The user is encouraged to click on a button in page 4 order to participate in the campaign and after clicking on this button, Internet users are redirected to additional pages containing purported testimonials from participants and further prompts encouraging them to continue the process. The Complainant suggests that this type of presentation is typical of fraudulent promotional schemes designed to create a sense of legitimacy and encourage users to proceed through successive steps. It says that the navigation on the website at the disputed domain name ultimately leads users to a form requesting personal information, including the user’s full name, age, mobile phone number, and place of residence and that the structure of the website therefore leads Internet users from an initial promotional message to a page collecting personal data and that this raises serious concerns of phishing or other fraudulent data collection practices. The Complainant submits that by using a misspelling of the Complainant’s CARREFOUR trade mark in the disputed domain name, reproducing the Complainant’s trade mark on the website itself, and presenting what appears to be a promotional campaign associated with the Complainant, the Respondent is clearly seeking to attract Internet users by creating a likelihood of confusion with the Complainant’s mark. Such conduct, says the Complainant, falls squarely within the circumstances of bad faith described in paragraph 4(b)(iv) of the Policy, namely the intentional attempt to attract, for commercial gain, Internet users to a website by creating a likelihood of confusion with a complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the website. This, submits the Complainant, is evidence of registration on bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 trade mark and the disputed domain name. WIPO Overview 3.1, section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the mark is recognisable within the disputed domain name, in that one letter of the CARREFOUR mark is omitted. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 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. 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 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. page 5 The Complainant has submitted that there is no evidence that the Respondent is commonly known by the disputed domain name, nor that it has authorised, licensed, or otherwise permitted the Respondent to use the CARREFOUR trade mark in any manner, including to register or use any domain name incorporating the CARREFOUR trade mark or a variation thereof. The Complainant has also submitted that the Respondent is not affiliated with the Complainant and there is no relationship between the Parties that could give rise to any right or legitimate interest in the disputed domain name. The Complainant has submitted that the Respondent is not using the disputed domain name in connection with any bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy. It has noted that the disputed domain name resolves to a website presenting what appears to be a promotional campaign using the wording “Carrefour” and inviting users to participate in a prize campaign purportedly offering a cash reward and that the website guides users through several steps to a form requesting personal information, including the user’s name, age, telephone number, and place of residence. There appears to be a significant likelihood that in the circumstances this is for the purposes of phishing and as noted by the Complainant, the use of a domain name for an illegal activity, including phishing or other fraudulent schemes, can never confer rights or legitimate interests on a respondent. The Complainant has also submitted that the Respondent is not making any legitimate noncommercial or fair use of the disputed domain name within the meaning of paragraph 4(c)(iii) of the Policy. According to the Complainant, the disputed domain name consists of a misspelling of the Complainant’s distinctive trade mark, and the associated website displays the wording “Carrefour” in Latin characters, thereby suggesting an association with the Complainant which does not exist and taking unfair advantage of its mark in a manner that cannot amount to legitimate noncommercial or fair use under the Policy. 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 the present case, the Panel notes that the Respondent registered the disputed domain name, which amounts to a misspelling and typosquatting of the Complainant’s trade mark long after the registration of the Complainant’s trade marks. The Complainant’s CARREFOUR mark and business is very well established and reputed in France and internationally. Considering its degree of distinctiveness, it is highly unlikely that the Respondent registered the disputed domain name without having had knowledge of the Complainant and of its trade mark rights. 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 3.1, section 3.2.1. Under paragraph 4(b)(iv) of the Policy there is evidence of registration and use of the disputed domain name in bad faith where a Respondent has used the disputed domain name to intentionally attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s trade marks as to the source, sponsorship, affiliation or endorsement of the website. page 6 By using a misspelling of the Complainant’s CARREFOUR trade mark in the disputed domain name, presenting the Complainant’s trade mark on the website to which the disputed domain name resolves and also presenting what appears to be a promotional campaign associated with the Complainant, the Panel notes that Respondent is clearly seeking to attract Internet users by creating a likelihood of confusion with the Complainant’s mark. This fulfills the requirements of paragraph 4(b)(iv) of the Policy and amounts to evidence of registration and use of the disputed domain name in bad faith. Panels have held that the use of a domain name for illegitimate activity, here, claimed to be phishing, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. As described by the Complainant, the website at the disputed domain name invites Internet users to participate in what is presented as a promotional campaign allegedly organized by “Carrefour”, offering participants the opportunity to win a cash prize of USD 500. The user is encouraged to click on a button in order to participate in the campaign and after clicking on this button, Internet users are redirected to additional pages containing purported testimonials from participants and further prompts encouraging them to continue the process. According to the Complainant’s translation of the website ( which is unchallenged) navigation on the website ultimately leads users to a form requesting personal information, including the user’s full name, age, mobile phone number, and place of residence and that the structure of the website therefore leads Internet users from an initial promotional message to a page collecting personal data. In circumstances that the Complainant is not associated with and has not authorised these arrangements there is an obvious and significant concern of phishing, or of other fraudulent data collection practices. This is further evidence of the registration and use of the disputed domain name in bad faith. 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 <carefour.sale> be transferred to the Complainant. /Alistair Payne/ Alistair Payne Sole Panelist Date: April 29, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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