Westmore · UDRP DecisionCarrefour.lol
The Panel ordered transfer of <carrefour.lol>. It found the domain identical to the Complainant’s CARREFOUR mark, found no rights or legitimate interests after the Respondent failed to rebut the Complainant’s prima facie case, and found bad-faith registration and use based on the mark’s longstanding worldwide recognition, the Complainant’s strong presence in Italy, the Respondent’s likely knowledge of the mark, and passive holding without any plausible good-faith use.
The timeline behind carrefour.lol
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.lol — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how an exact-match domain incorporating a longstanding, recognized trademark can satisfy all three UDRP elements even when the domain is merely inactive. The combination of exact identity, substantial trademark priority, geographic market presence in the Respondent’s country, no rebuttal, and no plausible good-faith use made passive holding decisive rather than neutral.
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. Nikhil Stolk Case No. D2026-2751 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins SAS, France. The Respondent is Nikhil Stolk, Italy. 2. The Domain Name and Registrar The disputed domain name <carrefour.lol> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 24, 2026. On June 25, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 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 (“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 June 29, 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 29, 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 30, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 20, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 24, 2026. page 2 The Center appointed Willem J. H. Leppink as the sole panelist in this matter on July 28, 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 following facts are undisputed. The Complainant is a retail company founded in 1968. It is listed on the CAC 40 index of the Paris Stock Exchange and operates in more than 14,000 stores across over 40 countries. In addition to retail activities, the company also provides services including travel, banking, insurance, and ticketing. The Complainant is the owner of numerous trademark registrations for the mark CARREFOUR, including international registrations and European Union registrations, as well as other trademarks comprising the term CARREFOUR, including: - the European Union trademark registration with registration number 5178371, registered on August 30, 2007, for goods and services in classes 9, 35 and 38; - the International trademark with registration number 351147, registered on October 2, 1968, covering goods and services from classes 1 to 34, designating various countries, including Italy; - the International trademark with registration number 353849, registered on February 28, 1969, for goods and services from classes 35 to 42, designating various countries, including Italy. The Complainant also owns domain names incorporating its mark, including the domain name <carrefour.com> (registered in 1995) and <carrefour.fr> (registered in 2005). The disputed domain name <carrefour.lol> was registered on June 10, 2026. At the time of rendering this Decision, the disputed domain name resolves to an inactive page displaying the page cannot be reached. 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. With more than 500,000 employees worldwide and millions of daily unique visitors in its stores, the Complainant is without a doubt one of the major and well-known worldwide leaders in retail. The CARREFOUR trademark enjoys a wide-spread continuous reputation, as stated by a large number of UDRP decisions, such as Carrefour SA v. Host Master, Njalla Okta LLC, WIPO Case No. D2026-1122, Carrefour SA v. jean noel ballart, WIPO Case No. D2023-2225 and Carrefour SA v. Sui Yuan, Bao Bao Liu, WIPO Case No. D2023-3003. The Complainant’s fame and notoriety is also evidenced on the Internet. For instance, the Complainant’s Facebook page is currently “liked” by more than 12 million Internet users. page 3 Moreover, the Complainant is well-known in Italy, where the Respondent supposedly resides. The Complainant has a significant commercial presence in Italy, with over 1,500 stores across 19 regions, and a dedicated website for its Italian customers. The disputed domain name is identical to its earlier CARREFOUR trademark and reproduces the CARREFOUR trademark in its entirety without any additional element. The use of the lower-case letter format on the one hand and the addition of the Top-Level Domain “.lol” on the other hand, are not significant in determining whether the disputed domain name is identical or confusingly similar to the trademarks of the Complainant. Therefore, the Complainant contends that the disputed domain name is identical to the Complainant’s earlier trademarks. The Respondent has no rights or legitimate interests in the disputed domain name. The Complainant’s searches revealed no CARREFOUR trademark owned by the Respondent, nor is there any evidence that the Respondent has been commonly known by the disputed domain name. The Respondent reproduces the Complainant’s well-known trademark without any license or authorization and has not used or made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services. The composition of the disputed domain name carries a high risk of implied affiliation with the Complainant, which cannot constitute fair use. Given that the Complainant’s trademark rights significantly predate the registration of the disputed domain name, the burden lies with the Respondent to establish any rights or legitimate interests. The Complainant has made a prima facie case in line with section 2.1 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), and none of the circumstances under which a respondent may demonstrate such rights are present here. The disputed domain name was registered and is being used in bad faith. Given the Complainant’s longstanding worldwide reputation, it is inconceivable that the Respondent was unaware of the CARREFOUR trademark at the time of registration. UDRP panels have consistently held that the mere registration of a domain name identical or confusingly similar to a famous trademark by an unaffiliated entity creates a presumption of bad faith. A basic trademark or search engine query would have revealed the Complainant’s rights, and the Respondent’s failure to conduct such a search is itself indicative of bad faith. The Respondent’s choice of the disputed domain name cannot have been accidental. It was most likely registered with the intent to attract Internet users searching for the Complainant’s products and services, which cannot constitute good faith use. By maintaining the disputed domain name, which resolves to an error page, the Respondent further prevents the Complainant from reflecting its trademark in the corresponding domain name. The disputed domain name does not resolve to an active website but to an error page. The non-use of a domain name does not prevent a finding of bad faith under the doctrine of passive holding. Given the Complainant’s longstanding international reputation, no conceivable good faith use of the disputed domain name by the Respondent can be envisaged. The Complainant therefore submits that the third element of the Policy is satisfied. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 4 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 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 identical to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith For the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) sets out circumstances which, if found by the Panel to be present, shall constitute evidence of registration and use of a domain name in bad faith. The Complainant’s CARREFOUR trademark enjoys longstanding and well-documented recognition worldwide. Given the global reputation of the mark, but also the strong presence of the Complainant in Italy, where the Respondent resides, the Panel finds it more likely than not that the Respondent was aware of the Complainant’s rights at the time of registration. The Panel therefore infers that the Respondent registered the disputed domain name with full knowledge of those rights and with the intention of creating a misleading association with the Complainant. The registration of a domain name that is identical to a famous trademark by an unaffiliated entity is sufficient to give rise to a presumption of bad faith. page 5 The disputed domain name does not resolve to an active website but to an error page. The Panel recalls that passive holding — including the non-use of a domain name — does not preclude a finding of bad faith (WIPO Overview 3.1, section 3.3). In light of the Complainant’s longstanding international reputation, the Panel can conceive of no plausible good faith use of the disputed domain name by the Respondent. Having reviewed the record, the Panel finds that the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. Accordingly, 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.lol> be transferred to the Complainant. /Willem J. H. Leppink/ Willem J. H. Leppink Sole Panelist Date: August 3, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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