ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Carrefour SA v. Hoang Vu, Bui Anh, Bao To Case No. D2025-3694 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondent is Hoang Vu, United States of America (“United States”), Bui Anh, United States, and Bao To, United States. 2. The Domain Names and Registrar The disputed domain names , , and are registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 11, 2025. On September 11, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On September 15, 2025, 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 (Domain Admin/Privacy Protect, LLC (PrivacyProtect.org)) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 18, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on September 19, 2025. 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”).
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 September 24, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 14, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 15, 2025. The Center appointed Karen Fong as the sole panelist in this matter on October 23, 2025. 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 one of the leading operators of hypermarkets under the name CARREFOUR. Currently, it operates more than 14,000 stores in over 40 countries. It has millions of daily unique visitors to its stores and a revenue of EUR 84.9 billion in 2023. It is listed on the index of the Paris Stock Exchange. The Complainant owns numerous trade mark registrations for CARREFOUR all over the world including the following: - International Trade Mark Registration No. 351147 for CARREFOUR, registered on October 2, 1968; - International Trade Mark Registration No. 353849 for CARREFOUR, registered on February 28, 1969; and - European Union Trade Mark Registration No. 005178371 for CARREFOUR, registered on August 30, 2007; (individually and collectively, the “Trade Mark”). The Complainant also owns and uses numerous domain names which comprise the Trade Mark including , , and . The Complainant submitted in evidence a large number of UDRP decisions were panels have stated that the Complainant and the Trade Mark are very well known. Its Facebook account is currently liked by more than 11 million users. The Respondents who appear to be of Vietnamese origin are listed as residing in the United States. The details of the disputed domain names are as follows: Disputed Domain Name Registrant /Respondents Creation Date Bui Anh August 17, 2025 Bao To August 25, 2025 Hoang Vu August 18, 2025 Bao To August 25, 2025 Bui Anh August 19, 2025 All the disputed domain names are inactive. 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 the disputed domain names are identical and/or confusingly similar to the Trade Mark in which it has rights, that the Respondents have no rights or legitimate interests with
page 3 respect to the disputed domain names, and that the disputed domain names were registered and are being used in bad faith. The Complainant requests transfer of the disputed domain names. B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the disputed domain names registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain names registrants pursuant to paragraph 10(e) of the Rules. The disputed domain names registrants did not comment on the Complainant’s request. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.11.2. As regards common control, the Panel notes the following: (1) All the disputed domain names comprise either the Trade Mark or a misspelling of the Trade Mark as part of the disputed domain names; (2) All the disputed domain names include geographical names of countries (or a misspelling of the same) in the Middle East as part of the disputed domain names – “uae”, “kuwait” and “kuwaite”; (3) All the disputed domain names were registered between August 17 to 25, 2025; (4) The email addresses of all the Respondents are Gmail accounts. In addition the email addresses of Bui Anh and Haong Vu share the same naming pattern – name, random numbers and letters; (5) The Respondents, Bao To and Hoang Vu, share the same street address, city, state, postal code, telephone and fax numbers; (6) The telephone number of Bao To and Hoang Vu corresponds to the area code for Connecticut and not Kissimmee (Florida) which is their alleged address whilst the telephone number for Bui Anh corresponds to the area code of New York rather than Mount Clemens, Michigan where she purports to reside; (7) All the disputed domain names are registered with the Registrar and are inactive. (8) The Respondents all failed to file responses. The evidence submitted points to the fact that all the disputed domain names are subject of common control by the Respondents. The above pattern evidences common conduct based on the registration and use of the disputed domain names and that such conduct interferes with the Trade Mark. The Respondents had
page 4 the opportunity but did not respond to the Complaint. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain names registrants (referred to below as “the Respondent”) in a single proceeding. B. 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 trade mark and the disputed domain name. WIPO Overview 3.0, section 1.7. Based on the available record, the Panel finds the Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the Trade Mark is reproduced within the four of disputed domain names whilst one of them consists of an obvious misspelling of the Trade Mark with an extra “f” next to the existing one. Accordingly, the disputed domain names are confusingly similar to the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. While the addition of the geographical and other terms here, “uae”, “kuwait”, “kuwaite” and “en”, may bear on assessment of the second and third elements, the Panel finds the addition of such terms and letters do not prevent a finding of confusing similarity between the disputed domain names and the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. Based on the available record, the Panel finds the first element of the Policy has been established. C. 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. While the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the often impossible 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. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain names. 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 names such as those enumerated in the Policy or otherwise. Based on the available record, the Panel finds the second element of the Policy has been established. D. 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.
page 5 In the present case, the Panel notes that the Respondent must have been aware of the Trade Mark when it registered the disputed domain names given the reputation of the Trade Mark. It is therefore implausible that the Respondent was unaware of the Complainant when it registered the disputed domain names. In the WIPO Overview 3.0, section 3.2.2 states as follows: “Noting the near instantaneous and global reach of the Internet and search engines, and particularly in circumstances where the complainant’s mark is widely known (including in its sector) or highly specific and a respondent cannot credibly claim to have been unaware of the mark (particularly in the case of domainers), panels have been prepared to infer that the respondent knew, or have found that the respondent should have known, that its registration would be identical or confusingly similar to a complainant’s mark. Further factors including the nature of the domain name, the chosen top-level domain, any use of the domain name, or any respondent pattern, may obviate a respondent’s claim not to have been aware of the complainant’s mark.” The fact that there is a clear absence of rights or legitimate interests coupled with the Respondent’s choice of the five disputed domain names without any explanation is also a significant factor to consider (as stated in WIPO Overview 3.0, section 3.2.1). The disputed domain names fall into the category stated above and the Panel finds that the registration is in bad faith. The Panel also notes that the disputed domain names are inactive. 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 3.0, section 3.2.1. Panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. Having reviewed the available record, the Panel finds the non-use of the disputed domain names do not prevent a finding of bad faith in the circumstances of this proceeding. Although panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark; (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use; (iii) the respondent’s concealing its identity or use of false contact details (noted to be in breach of its registration agreement); and (iv) the implausibility of any good faith use to which the domain name may be put. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Trade Mark, the composition of the disputed domain names, the false address and contact details provided by the Respondent when registering the disputed domain names (the Written Notice was not able to be delivered by the courier service as all three addresses were listed as “bad address”), and lack of a response from the Respondent, 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. 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 names , , , and be transferred to the Complainant. /Karen Fong/ Karen Fong Sole Panelist Date: November 11, 2025
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