Westmore · UDRP DecisionCarrefour-clientes.app
The Panel ordered transfer of <carrefour-clientes.app>. It found the domain confusingly similar because it incorporated the CARREFOUR mark in its entirety and the addition of “clientes” did not prevent confusing similarity. The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests, while the domain’s composition created a risk of implied affiliation. Bad faith was established from the Respondent’s targeting of the well-established CARREFOUR mark, the domain’s Spanish customer-oriented wording, its prior use for a login page impersonating the Complainant’s payment services, and its subsequent passive holding.
The timeline behind carrefour-clientes.app
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 carrefour-clientes.app — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain combining an established mark with a customer-facing term can support findings across all three UDRP elements when the domain has also been used for an impersonating login page. It also shows that discontinuing the active content and leaving the domain inactive does not cure bad faith where the totality of the record demonstrates deliberate targeting.
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. Diego Cisneros Ramos Case No. D2026-1549 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins SAS, France. The Respondent is Diego Cisneros Ramos, Spain. 2. The Domain Name and Registrar The disputed domain name <carrefour-clientes.app> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 13, 2026. On April 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 14, 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 (Redacted for Privacy, Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 15, 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 April 15, 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 April 22, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 12, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 13, 2026. The Center appointed Miguel B. O’Farrell as the sole panelist in this matter on May 18, 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 pioneer of the concept of hypermarkets back in 1968. With a total revenue amounting to approximately 87,2 billion euros in 2024, the Complainant operates more than 14,000 stores in more than 40 countries worldwide. With more than 500,000 employees worldwide and millions of daily unique visitors in its stores, the Complainant is a worldwide leader in retail. . The Complainant additionally offers travel, banking, insurance and ticketing services. The Complainant owns several hundred trademark registrations worldwide for the CARREFOUR term, including the following: International trademark CARREFOUR No. 351147, registered on October 2, 1968, duly renewed, and designating goods in international classes 1 to 34; International trademark CARREFOUR No. 353849, registered on February 28, 1969, duly renewed, and designating services in international classes 35 to 42; European Union trademark CARREFOUR No. 5178371, registered on August 30, 2007, duly renewed, and designating goods and services in international classes 9, 35 and 38. In addition, the Complainant is also the owner of numerous domain names identical to, or comprising, its trademarks, both within generic and country-code Top-Level Domains. For instance, <carrefour.com> has been registered since 1995, <carrefour.fr> since 2005 and <pass-carrefour.com> since 2019. Previous UDRP panels have acknowledged that CARREFOUR is a well-known trademark by saying the following: “... given the fact that the Complainant’s CARREFOUR trademarks are well-known worldwide and distinctive, the Respondent cannot credibly claim to have been unaware of the existence of the previous trademarks.” Carrefour SA v. jean noel ballart, WIPO Case No. D2023-2225; “The Complainant’s trademark is well-known and has strong international reputation and online visibility.” Carrefour SA v. Sui Yuan, Bao Bao Liu, WIPO Case No. D2023-3003, and “... the disputed domain names incorporate the entirety of the Complainant’s well-known trademarks CARREFOUR...” Carrefour SA v. hanib bas, WIPO Case No. D2020-1798. The disputed domain name was registered on March 29, 2026 and currently does not resolve to an active webpage. It previously resolved to a login page that impersonated the Complainant’s payment services and mimicked the official URL structure of the Complainant’s Spanish site at “www.pass.carrefour.es”. 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 its trademark CARREFOUR, that the Respondent has no rights or legitimate interests in the disputed domain name, which it has registered and uses in bad faith. The Complainant requests the Panel to issue a decision ordering the transfer of the disputed domain name to the Complainant. page 3 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 trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“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 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 3.1, section 1.7. Although the addition of other terms here, “clientes” may bear on assessment of the second and third elements, the Panel finds the addition of such 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 3.1, section 1.8. The Panel will discard the Top-Level Domain (“TLD”) “.app” from its confusing similarity test. 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. 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 composition of the disputed domain carries a risk of implied affiliation with the Complainant and its trademark. WIPO Overview 3.1, section 2.5.1 The Panel finds that the second element of the Policy has been established. page 4 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. The Panel is satisfied that the Respondent must have been aware of the Complainant’s business, the trademark CARREFOUR mentioned in Section 4 above, and also the Complainant’s website when the Respondent registered the disputed domain name. By that time the Complainant had registered and had been using the trademark CARREFOUR worldwide for many years. By registering the disputed domain name, the Respondent was targeting the Complainant and its business by incorporating the Complainant’s trademark CARREFOUR in its entirety. The inclusion of the Spanish word “clientes” (in English “clients”) in the disputed domain name contributes to lead Internet consumers think that it belongs to or is sponsored by the Complainant, which is not the case. The use made by the Respondent’s website at the disputed domain name would lead Internet users to mistakenly think that the website is an official website of the Complainant, or endorsed by it, and thereby the Respondent could capitalize on the reputation of the trademark CARREFOUR for its own commercial benefit. The clear absence of rights or legitimate interests coupled with no explanation for the Respondent’s choice of the disputed domain name, the nature of the disputed domain name, and the previous content and change of the website at the disputed domain name could only be indicative of bad faith (as stated in section 3.2.1 of WIPO Overview 3.1). Panels have found that the non-use of a domain name (including a blank or “coming soon” page) 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 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 current passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes 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 <carrefour-clientes.app> be transferred to the Complainant. /Miguel B. O’Farrell/ Miguel B. O’Farrell Sole Panelist Date: June 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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