Westmore · UDRP decision
WIPO · Case No. D2026-2238

Eureca-carrefour.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <eureca-carrefour.com>. It found the domain confusingly similar to the Complainant’s CARREFOUR mark because the mark remained recognizable despite the addition of “eureca.” The Respondent had not been authorized, was not commonly known by the domain, and presented no evidence of bona fide, legitimate noncommercial, or fair use. Bad faith was established from the totality of circumstances, including the reputation of the CARREFOUR mark, the domain’s composition, the Respondent’s domicile in France, the lack of a response, and passive holding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-07-15
Panelist(s)
Haas, Marie-Emmanuelle
Complainant
Carrefour SA
Respondent
Thomas Lavoine
Counsel
IP Twins, S.A.S
Disputed domain(s)
eureca-carrefour.com
Domain history UDRP Intelligence

The timeline behind eureca-carrefour.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 eureca-carrefour.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 eureca-carrefour.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain that combines a well-known mark with a term linked to the complainant’s own operations can support findings across all three UDRP elements, even when the domain is inactive. The bad-faith determination rested on the totality of the circumstances rather than evidence of an active fraudulent or commercial website.

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
2026-07-15
Panel
Haas, Marie-Emmanuelle
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Carrefour SA v. Thomas Lavoine Case No. D2026-2238 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins SAS, France. The Respondent is Thomas Lavoine, France. 2. The Domain Name and Registrar The disputed domain name <eureca-carrefour.com> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 25, 2026. On May 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 26, 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 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 June 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 23, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 24, 2026. The Center appointed Marie-Emmanuelle Haas as the sole panelist in this matter on July 1, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant, Carrefour SA, is one of the worldwide leaders in retail and a pioneer of the concept of hypermarkets back in 1968. With a total revenue amounting to approximately EUR 87.2 billion in 2024, the Complainant is listed on the CAC 40 index of the Paris Stock Exchange. It operates more than 14,000 stores in more than 40 countries worldwide. With more than 500,000 employees worldwide and 1 million daily unique visitors in its stores, the Complainant is worldwide well known in retail. It additionally offers travel, banking, insurance, and ticketing services. Eureca is the name of the Complainant’s European purchasing platform. The Complainant is the owner of numerous trademarks, and notably of the following trademarks, all registered prior to the disputed domain name: - 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; and - 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. The Complainant submits that the earlier trademarks CARREFOUR enjoy a wide-spread continuous reputation, as stated by a large number of UDRP decisions. The Complainant’s fame and notoriety is also evidenced on the Internet. Indeed, the Complainant’s Facebook page is currently “liked” by more than 12 million Internet users. The Complainant also owns numerous domain names integrating “CARREFOUR” such as <carrefour.com> and <carrefour.fr>. The disputed domain name was registered on May 5, 2026, in the name of an individual domiciled in France. 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 the following. On the first element, The disputed domain name is confusingly similar to its earlier well-known CARREFOUR trademarks, which are entirely reproduced and immediately recognizable in the disputed domain name. Indeed, the disputed domain name incorporates the earlier trademarks of the Complainant, preceded by the term “eureca”, separated by a hyphen. The term “eureca” is a notorious exclamation attributed to ancient Greek mathematician Archimedes. Moreover, the combination of “eureca” and “carrefour” cannot be a coincidence, as Eureca corresponds to the name of the Complainant’s European purchasing platform. page 3 On the second element, There is no evidence that the Respondent has been commonly known by the disputed domain name as an individual, business, or other organization. He was not granted any license or authorization to register the disputed domain name or to use the CARREFOUR trademark, The Respondent has not, before the original filing of the Complaint, used or made preparations to use the disputed domain name in relation to a bona fide offering of goods or services. At the time of the original filing of the Complaint, no active website was associated with the disputed domain name, and the domain name resolved to a standard landing page provided by the Registrar. On the third element, Given the global renown of the CARREFOUR trademark, the Respondent necessarily had the Complainant’s name and trademarks in mind when registering the disputed domain name. The Respondent’s choice of the disputed domain name cannot have been accidental. The non-use of a domain name does not prevent the finding of bad faith under the doctrine of passive holding. 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 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. The Panel finds the CARREFOUR mark is recognizable 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, “eureca” 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 CARREFOUR 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 Pursuant to paragraph 4(c) of the Policy, the Respondent may establish rights or legitimate interests in the disputed domain name by demonstrating any of the following: page 4 (i) before any notice to it of the dispute, the Respondent’s use of, or demonstrable preparations to 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; or (ii) the Respondent has been commonly known by the disputed domain name, even if it has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate non-commercial or fair use of the disputed domain name, without intent for commercial gain, to misleadingly divert consumers, or to tarnish the trademark or service mark at issue. 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. The Respondent was not authorized to use or register the disputed domain name, and neither made any bona fide use of the disputed domain name (or demonstrable plans for such use), nor any legitimate noncommercial or fair use. Moreover, it is not commonly known by the disputed domain name. 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. This list of non-exhaustive circumstances is as follows: (i) circumstances indicating that the Respondent has registered, or the Respondent has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the disputed domain name registration to the Complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or (ii) the Respondent has registered the disputed domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the Respondent has engaged in a pattern of such conduct; or (iii) the Respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or page 5 (iv) by using the domain name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on the respondent’s website or location. As already explained, 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. In the present case, the Panel notes that the Respondent, who is domiciled in France, could not have been unaware of the Complainant’s well-known CARREFOUR trademark, when it decided to register the disputed domain.name. 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 reputation of the Complainant’s trademark, the composition of the disputed domain name, and lack of response, 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 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 <eureca-carrefour.com> be transferred to the Complainant. /Marie-Emmanuelle Haas/ Marie-Emmanuelle Haas Sole Panelist Date: July 15, 2026

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

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