Westmore · UDRP DecisionSodexocorporate.com
The Panel ordered transfer of <sodexocorporate.com> after finding all three UDRP elements established. The domain incorporated the SODEXO mark in full with the term “corporate,” creating confusing similarity and suggesting an official corporate presence. The Respondent presented no rights or legitimate interests. Bad faith was established from the deliberate targeting of the distinctive and well-known mark, apparently inaccurate registration data and likely unauthorized use of another person’s identity, and passive holding in the totality of the circumstances. The Panel did not rely on the Complainant’s unsupported concern about phishing or infer a pattern involving another domain name.
The timeline behind sodexocorporate.com
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The decision illustrates how a domain combining an entire distinctive mark with “corporate” may both satisfy confusing similarity and strengthen findings of implied affiliation and targeting. It also shows that passive holding may support bad faith even when registrar intervention contributed to the domain’s inactivity, provided the totality of the record supports that conclusion. The Panel carefully confined its reasoning to established facts by declining to rely on unsupported phishing concerns or an unproven pattern involving another domain.
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 SODEXO v. Name Redacted Case No. D2026-2098 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 <sodexocorporate.com> is registered with http.net Internet GmbH (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 15, 2026. On May 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 9, 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 / Redacted) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 9, 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 June 10, 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”). 1 The Respondent appears to have used the name of a third party when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this Decision. The Panel has attached as Annex 1 to this Decision an order to the Registrar providing for transfer of the domain name that includes the name of the registrant disclosed by the Registrar. The Panel has directed the Center to transmit Annex 1 to the Registrar as part of the order in these proceedings, but has further directed 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 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 11, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 1, 2026. The Center received an email communication on June 28, 2026, that appears, on its face, to be from the individual identified in the Registrar-disclosed registrant information, stating that the disputed domain name had not been registered by that individual and that the individual’s identity appeared to have been used without authorization. No Response was filed with the Center. Accordingly, on July 8, 2026, the Center notified the Parties that it would proceed to panel appointment. The Center appointed Elise Dufour as the sole panelist in this matter on July 10, 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 is a French company founded in 1966. It provides food services and facilities management services worldwide, operating in a large number of countries and employing several hundred thousand people. Until 2008, the Complainant conducted its business under the name and mark SODEXHO (formerly SODEXHO ALLIANCE), the spelling of which was then simplified to SODEXO. The Complainant is the owner of a substantial portfolio of trademark registrations for SODEXO and SODEXHO in jurisdictions around the world, as evidenced by the annexes to the amended Complaint. These include, among others: - European Union trademark registration No. 008346462 for the word mark SODEXO, registered on February 1, 2010, covering goods and services in classes 9, 16, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45; - European Union trademark registration No. 006104657 for the semi-figurative mark SODEXO, registered on June 27, 2008, covering goods and services in the same classes; - French trademark registration No. 3513766 for the semi-figurative mark SODEXO, registered on December 21, 2007, covering goods and services in the same classes; and - French trademark registration No. 4697571 for the word mark SODEXO, registered on March 12, 2021, covering goods and services in classes 7, 29, 30, 32, 33, and 35. The Complainant also operates a number of domain names incorporating its mark, including <sodexo.com> and <sodexo.fr>. The disputed domain name was registered on May 9, 2026. It does not resolve to an active website. In its verification response, the Registrar stated that it had blocked the disputed domain name in the DNS on the day following its registration and had also blocked the corresponding customer account, having been alerted to the term “sodexo” by a complaint concerning another domain name, and that the account holder neither contested those measures nor replied to any of the Registrar’s communications. The registration data disclosed by the Registrar identifies the registrant as an individual located in France. On June 28, 2026, the Center received an email communication sent from an email address other than the one recorded in the registration data for the disputed domain name from a person bearing the name and postal address of the registrant disclosed by the Registrar. That person stated that she had not registered the disputed domain name, that the email address and telephone number recorded in the registration data were not hers, and that her identity appeared to have been used without her authorization. page 3 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 reproduces in its entirety its SODEXO mark, which it describes as fanciful and well known, with the mere addition of the generic English term “corporate”, which is not apt to distinguish the disputed domain name from that mark. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name, being neither commonly known by it nor affiliated with, licensed by, or otherwise authorized by the Complainant. The Complainant further contends that, given the reputation of its mark, the Respondent could not have been unaware of the Complainant’s rights when registering the disputed domain name, that the absence of any active website does not prevent a finding of bad faith, and that the Complainant fears a fraudulent use of the disputed domain name for phishing purposes. B. Respondent The Respondent did not reply to the Complainant’s contentions. The communication received by the Center on June 28, 2026 is addressed in section 6 below. 6. Discussion and Findings Preliminary Issue: Identity of the Respondent The Registrar disclosed as registrant of the disputed domain name an individual located in France. On June 28, 2026, the Center received a communication from a person bearing that name and postal address, stating that she had not registered the disputed domain name and that her identity had been used without her authorization. The Panel is not in a position to verify that assertion. The Panel notes, however, that several elements on the record are consistent with it. The communication was sent from an email address other than the one recorded in the registration data, which accords with the statement that the recorded email address and telephone number do not belong to that person. The Center’s written communication dispatched to the postal address recorded in the registration data evidently reached that person, who reacted to it within the period allowed for the submission of a Response. The Registrar, for its part, has indicated that the account holder behind the registration neither contested to the blocking of the disputed domain name and of the account nor replied to any of the Registrar’s communications. Having regard to the potential identity theft, the Panel has redacted the name of the registrant from this Decision, in the manner and for the reasons set out in footnote 1 above. 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. page 4 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 “corporate”, 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. Two of the trademark registrations referred to above are semi-figurative. As figurative elements are incapable of representation in a domain name, they are disregarded for the purposes of the present comparison, which bears on the verbal element “Sodexo”. WIPO Overview 3.1, section 1.10. The Top-Level Domain “.com” is a standard registration requirement and is likewise disregarded. WIPO Overview 3.1, 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 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. There is nothing on the record to suggest that the Respondent is or has been commonly known by the disputed domain name, or that the Respondent used, or made demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Nor is there any indication of a legitimate noncommercial or fair use. The Panel further notes that the disputed domain name combines the Complainant’s mark, a coined term, with the term “corporate”, so composed as to suggest an official corporate presence of the Complainant. Such a composition carries a risk of implied affiliation and cannot constitute fair use. WIPO Overview 3.1, section 2.5.1. 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. The Panel observes that SODEXO is a coined term, having no apparent meaning independent of the Complainant’s business, and that the well-known character of the Complainant’s mark has been recognized in numerous prior decisions under the Policy. The Complainant’s trademark rights long predate the page 5 registration of the disputed domain name on May 9, 2026. The disputed domain name reproduces that mark in its entirety and combines it with the term “corporate”, a combination apt to be read as designating an official corporate presence of the Complainant. In these circumstances, the Panel finds it implausible that the disputed domain name could have been registered without knowledge of the Complainant and its mark, and finds that the Respondent deliberately targeted that mark. 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. The Panel further notes that the contact details recorded for the disputed domain name include an email address and a telephone number which the person named as registrant has stated are not hers, and that the record indicates that her identity was most likely used without her authorization. The provision of inaccurate registration data, and seemingly the use of the name and contact details of an unrelated individual constitute in the circumstances of this case an additional indication of bad faith. As to use, the disputed domain name does not resolve to an active website. The Panel notes that this could result from the measures taken by the Registrar which blocked the disputed domain name on the day following its registration. 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 distinctiveness and reputation of the Complainant’s trademark, the composition of the disputed domain name, the inaccuracy of the registration data, the failure of the Respondent to submit a response or to provide any evidence of actual or contemplated good faith use, 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. For the sake of completeness, the Panel adds two observations. First, the Complainant expresses the fear that the disputed domain name might be used for phishing purposes; the record contains no evidence of any such use, and the Panel’s findings do not rest on that assertion. Second, while the Registrar has indicated that it received a complaint concerning another domain name incorporating the term “sodexo”, the record does not establish that this other domain name was registered by the same person, and the Panel accordingly draws no inference of a pattern of conduct within the meaning of paragraph 4(b)(ii) of 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 <sodexocorporate.com> be transferred to the Complainant. /Elise Dufour/ Elise Dufour Sole Panelist Date: July 24, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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