Westmore · UDRP DecisionCarrefour-clientes-web.com, Carrefour-online-cliente.com, Clientes-carrefour.com
The Panel ordered transfer of all three disputed domain names. It found them confusingly similar to Carrefour SA’s CARREFOUR mark, found no rights or legitimate interests because the Complainant’s prima facie case was unrebutted and the domains created a risk of implied affiliation or were associated with a security alert, and found bad-faith registration and use based on the well-known mark, the domains’ composition, passive holding of two domains, and the use associated with the third domain.
The timeline behind carrefour-clientes-web.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 carrefour-clientes-web.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a group of domains combining a well-known mark with customer-service and Internet-related wording can satisfy all three UDRP elements even where two domains are inactive. The Panel relied on the mark’s reputation, the domains’ composition, the implied-affiliation risk, passive holding, and a security alert, while carefully referring to the suspected harmful activity as claimed phishing, malware, or fraud.
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. perpe, paco manelas Case No. D2026-2218 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins SAS, France. The Respondent is perpe, paco manelas, American Samoa, United States of America. 2. The Domain Names and Registrar The disputed domain names <carrefour-clientes-web.com>, <carrefour-online-cliente.com> and <clientes-carrefour.com> are registered with Nicenic International Group Co., Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 22, 2026. On May 22, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On May 23, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 27, 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 May 28, 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 May 29, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 18, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 19, 2026. page 2 The Center appointed Tobias Malte Müller as the sole panelist in this matter on June 24, 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 It results from the Complainant’s undisputed allegations that it is a worldwide leader in retail and a pioneer of the concept of hypermarkets back in 1968 and is listed on the CAC 40 index of the Paris Stock Exchange. The Complainant operates more than 14,000 stores in more than 40 countries, with more than 500,000 employees and millions of daily unique visitors in its stores. It additionally offers travel, banking, insurance and ticketing services. The Complainant is the registered owner of several trademarks worldwide for CARREFOUR, e.g., European Union Trademark Registration No. 005178371, CARREFOUR (word) registered on August 30, 2007 for goods and services in classes 9, 35 and 38. In addition, it owns many domain names containing CARREFOUR, e.g., <carrefour.com>, registered on October 25, 1995, and which resolves to its official website. The disputed domain names are <carrefour-clientes-web.com>, <carrefour-online-cliente.com> and <clientes-carrefour.com> and were registered on May 12, 2026, on May 13, 2026 and on April 9, 2026 respectively. Furthermore, the undisputed evidence provided by the Complainant proves that no active website is associated with the disputed domain names <carrefour-clientes-web.com> and <carrefour-online- cliente.com>, and they resolved to error pages. The disputed domain name <clientes-carrefour.com> triggers a security alert. 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 names. Notably, the Complainant contends that: (1) the disputed domain names are confusingly similar to the Complainant’s registered well-known trademark CARREFOUR, which is entirely reproduced in the disputed domain names and is immediately recognizable. It is well-established case law that the mere addition of generic terms, such as “cliente/clientes” (“client/clients” in Spanish), “web” and “online”, to a trademark, within a domain name does nothing to diminish the likelihood of confusion arising from that domain name and that the hyphen is of negligible significance when assessing confusing similarity; (2) the Respondent has no rights or legitimate interests in the disputed domain names. According to the Complainant, there are no CARREFOUR (or term similar thereto) trademarks owned by the Respondent; there is no evidence that the Respondent has been commonly known by the disputed domain names as an individual, business, or other organization and the Respondent reproduces the Complainant’s earlier registered trademarks in the disputed domain names without any license or authorization from the Complainant. At the time of the original filing of the Complaint, no active website was associated with the disputed domain names <carrefour-clientes-web.com> and <carrefour-online-cliente.com>, and the domain names resolved to error pages. Instead, navigation towards the disputed domain name <clientes- carrefour.com> was blocked to Complainant’s representative by the browser’s Phishing and Malware Protection feature and the following warning message appeared: “Dangerous site. Attackers on the site you page 3 tried visiting might trick you into installing software or revealing things like your passwords, phone, or credit card numbers. Chrome strongly recommends going back to safety.” In addition, in light of the worldwide renown of the Complainant’s trademarks, the Complainant sees no plausible use of the domain names that would be legitimate fair and non-commercial; (3) the disputed domain names were registered and were being used in bad faith. According to the Complainant, the Respondent’s choice of domain names cannot have been accidental and must have been influenced by the fame of the Complainant and its earlier trademarks. The above is further confirmed by the fact that the Respondent has already been involved in prior UDRP proceedings concerning the registration of domain names confusingly similar to CARREFOUR, thereby highlighting a pattern of cybersquatting conduct. In addition, the disputed domain names <carrefour-clientes-web.com> and <carrefour-online-cliente.com> are not associated with any active website and they resolve to error pages. The non-use of a domain name (including a blank or error page) does not prevent a finding of bad faith under the doctrine of passive holding. Moreover, the use of a domain name in connection with a website containing potentially harmful material or used for fraudulent purposes (such as phishing), as reported by Google Safe Browsing for <clientes- carrefour.com>, cannot be regarded as a good faith use under the Policy. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs this Panel to “decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. Paragraph 4(a) of the Policy requires a complainant to prove each of the following three elements in order to obtain an order that each disputed domain name be transferred or cancelled: (i) the disputed domain names are 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 names; and (iii) the disputed domain names have been registered and are being used in bad faith. The Panel will therefore proceed to analyze whether the three elements of paragraph 4(a) of the Policy are satisfied. 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 names. Accordingly, the disputed domain names are 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” (corresponding to “clients” in English) and “web” in the disputed domain name <carrefour-clientes-web.com>, and “online” and “cliente” (corresponding to “client” in English) in the disputed domain name <carrefour-online-cliente.com> and “clientes” in the disputed domain page 4 name <clientes-carrefour.com> may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the mark for the purposes of the Policy, WIPO Overview 3.1, section 1.8. 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. Moreover, the Panel notes that the disputed domain names <carrefour-clientes-web.com> and <carrefour- online-cliente.com> contain the Complainant’s registered and well-known trademark CARREFOUR entirely, plus the terms “clientes”/ “cliente” and the terms “web” and “online”, respectively. The nature of these disputed domain names carries a risk of implied affiliation: in fact, terms with an “inherent Internet connotation”, such as “web” and “online”, are seen as tending to suggest sponsorship or endorsement by the trademark owner, see WIPO Overview 3.1 at section 2.5.1. Furthermore, regarding the disputed domain name <clientes-carrefour.com>, which triggers a security alert, panels have held that the use of a domain name for illegal activity here, claimed phishing, distributing malware, or other types of fraud can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. 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. In the present case, the Panel shares the view of other UDRP panels and finds that the Complainant’s trademark CARREFOUR is well known. Therefore, this Panel has no doubt that the Respondent positively knew or should have known the Complainant’s trademark when registering the disputed domain names. This is underlined by the fact that the disputed domain names are clearly constituted by the Complainant’s trademark CARREFOUR plus the terms “clientes”/ “cliente” and the terms “web” and “online”, respectively. Panels have consistently found that the mere registration of a domain name that is identical or 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 3.1 section 3.1.4. The Panel shares this view. page 5 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 CARREFOUR trademark, and the composition of the disputed domain names <carrefour-clientes-web.com> and <carrefour-online-cliente.com>, and finds that in the circumstances of this case the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy. Furthermore, regarding the disputed domain name <clientes-carrefour.com>, panels have held that the use of a domain name for illegal activity here, claimed phishing, distributing malware or other types of fraud 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 <clientes-carrefour.com> 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-web.com>, <carrefour-online-cliente.com>, and <clientes-carrefour.com> be transferred to the Complainant. /Tobias Malte Müller/ Tobias Malte Müller Sole Panelist Date: July 8, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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