Westmore · UDRP DecisionCarrefourromaniasa.com
The Panel ordered transfer of <carrefourromaniasa.com> to Carrefour SA. It found the domain confusingly similar to the CARREFOUR mark because it reproduced the mark in full and the additional terms “romania” and “sa” did not avoid confusing similarity. The Respondent did not rebut the Complainant’s prima facie showing of no rights or legitimate interests. Although the domain displayed only a standard hosting-provider landing page, the Panel found bad faith under the passive-holding doctrine, relying on the well-known character of the mark and the domain’s apparent reference to the Complainant’s Romania-based company or office.
The timeline behind carrefourromaniasa.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 carrefourromaniasa.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining an entire well-known mark with geographic and corporate-form terms can strengthen, rather than dispel, an apparent connection to a complainant’s national operation. It also demonstrates that a default hosting page does not necessarily defeat bad faith where the totality of circumstances supports passive holding.
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. HOUNAS MICHAEL Case No. D2026-3254 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins SAS, France. The Respondent is HOUNAS MICHAEL, Greece. 2. The Domain Name and Registrar The disputed domain name <carrefourromaniasa.com> is registered with Register SPA (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 23, 2026. On July 23, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 27, 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) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 28, 2026, p roviding 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 August 4, 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 August 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 27, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 31, 2026. The Center appointed Petter Rindforth as the sole panelist in this matter on September 9, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration page 2 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 1959, operating in the hypermarket business. The Complainant also operates in Romania through its subsidiary Carrefour Romania S.A. The Complainant is the owner of the CARREFOUR trademark, registered in several countries and regions, including: - European Union Trade Mark registration No. 005178371 CARREFOUR (word), registered on August 30, 2007 for goods and services in Intl Classes 9, 35 and 38; - International Trademark registration No. 353849 CARREFOUR (fig), registered on February 28, 1969, for services in Intl Classes 35, 36, 37, 38, 39, 40, 41 and 42, designating many different jurisdictions; and The Complainant is also the owner of the domain names <carrefour.com>, registered on October 25, 1995, <carrefour.net>, registered on June 18, 2001, <carrefour.fr >, registered on June 23, 2005, and <carrefour.eu>, registered on March 10, 2006. The disputed domain name <carrefourromaniasa.com> was registered on July 9, 2026.. It is linked to a default landing page provided by the hosting provider Hostinger, with the message “You Are All Set to Go!” No further information is available on the Respondent, apart from what is stated by the Complainant. 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 Complainant is a major and well-known worldwide leader in retail, and that the Complainant enjoys a significant online presence across multiple social media platforms, followed by millions of users worldwide. The disputed domain name <carrefourromaniasa.com> incorporates the Complainant’s CARREFOUR trademark in its entirety as its leading and dominant element. The addition of the terms “romania” and “sa” does not prevent a finding of confusing similarity. On the contrary, these terms reinforce the association with the Complainant. ” Romania refers to the country in which the Complainant operates through its Romanian subsidiary, while “SA” is the common abbreviation for –“ societate pe acțiuni”, the Romanian equivalent of a public limited company. This combination is highly specific and leaves no plausible explanation other than an intentional reference to the Complainant and its Romanian operations. The Respondent therefore did not merely target the Complainant’s trademark. The Respondent sought to impersonate one of the Complainant’s corporate entities by creating a domain name that Internet users would naturally expect to identify the Complainant’s official Romanian company. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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, “romania” and “sa” may bear on assessment of the second and third elements, t he Panel finds the addition of such terms 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 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 disputed domain name resolves to a standard landing page provided by a hosting provider, displaying the message “You Are All Set to Go!” together with ordinary links concerning website migration and WordPress installation. In the absence of any evidence demonstrating a bona fide offering of goods or services, legitimate noncommercial or fair use, or any other basis for rights or legitimate interests, the Panel finds that the Respondent has failed to rebut the Complainant’s prima facie case The Panel finds 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. 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. 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 that the Complainant’s trademark is well-known, the disputed domain name is likely constructed to refer to the Complainant’s Romania based company/office. The Panel 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 <carrefourromaniasa.com> be transferred to the Complainant. /Petter Rindforth/ Petter Rindforth Sole Panelist Date: September 25, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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