ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Carrefour SA v. fa fa Case No. D2025-4018 1. The Parties The Complainant is Carrefour SA, France, represented by IP Twins, France. The Respondent is fa fa, Hong Kong, China. 2. The Domain Names and Registrar The disputed domain names , , , , and are registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 1, 2025. On October 2, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On October 3, 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 (Registration Private / Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 10, 2025, 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 October 10, 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on October 16, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 5, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 6, 2025.
page 2 The Center appointed Munir Suboh as the sole panelist in this matter on November 13, 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 Carrefour SA. The Complainant is one of the worldwide leaders in retail and a pioneer of the concept of hypermarkets back in 1968. With a published revenue of EUR 84.9 billion in 2023, the Complainant is listed on the index of the Paris Stock Exchange (CAC 40). The Complainant operates more than 14,000 stores in more than 40 countries worldwide. With more than 500,000 employees worldwide and millions of daily unique visitors in its stores. The Complainant additionally offers travel, banking, insurance and ticketing services. The Complainant owns several trademarks in multiple jurisdictions for CARREFOUR. In particular, the Complainant is the owner of the following trademarks registered well before the registration of the disputed domain names: - 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. 005178371, registered on August 30, 2007, duly renewed, and designating goods and services in international classes 9, 35, and 38. In addition, the Complainant is also the owner of numerous domain names comprising its CARREFOUR trademarks, both under generic Top-Level Domains (“gTLD”) and country-code Top-Level Domains (“ccTLD”). For instance, which has been registered since 1995. The Complainant’s notoriety is also evidenced on social media. For instance, its Facebook page has more than 12 million followers. The disputed domain names were all registered on August 16, 2025. All of the disputed domain names currently resolve to error pages. However, previously on August 18, 2025, the disputed domain names, and , resolved to websites bearing the logo and trademark of the Complainant, photos of its stores, and buttons labelled “Recharge”, “App”, “Withdraw”, and “Company Profile”. 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: (i) The disputed domain names are confusingly similar to its earlier well-known trademarks. Indeed, the disputed domain names reproduce the earlier CARREFOUR trademarks of the Complainant their entirety, together with the generic word “mall”. It is well established that the addition of a generic term to a well-known trademark in a domain name does not prevent a finding of confusing similarity.
page 3 (ii) The Complainant contends that the Respondent should be considered as having no rights or legitimate interests in respect of the disputed domain names that are the subject of the Complaint. Firstly, the Complainant performed searches and found no CARREFOUR trademark owned by the Respondent “fa fa”. From this finding, the Complainant asserts that the Respondent has acquired no trademark in the name CARREFOUR which could have granted the Respondent rights in the disputed domain names. Furthermore, the Complainant has found no evidence whatsoever that the Respondent is known by the disputed domain names. Secondly, the Respondent reproduces the Complainant’s earlier registered trademarks CARREFOUR in the disputed domain names without any licence or authorisation from the Complainant, which is strong evidence of the lack of legitimate interest. Thirdly, the Complainant puts forth that the Respondent has not, before the original filing of the Complaint, used or made preparations to use the disputed domain names in relation to a bona fide offering of goods or services. All of the disputed domain names currently resolve to error pages. Previously, the disputed domain names, and , resolved to websites bearing the logo and trademark of the Complainant, photos of its stores, and buttons labelled “Recharge”, “App”, “Withdraw”, and “Company Profile”. These elements cannot be considered a mere coincidence, but rather an attempt by the Respondent to trade off the goodwill associated with the well-known CARREFOUR trademarks and mislead Internet users into believing that the Respondent’s websites at the disputed domain names were directly operated by, authorised by, or affiliated with, the Complainant. Such use can never confer rights or legitimate interest. (iii) The Complainant submits that the specific composition of the disputed domain names, as well as the use of the Complainant’s marks on websites previously accessible on the two disputed domain names and , leave no doubt that the Respondent was aware of the existence of the Complainant and its earlier rights. The Respondent necessarily had the Complainant’s name and trademarks in mind when registering the disputed domain names. The Respondent’s choice of the disputed domain names cannot have been accidental and must have been influenced by the fame of the Complainant and its earlier trademarks. The Complainant’s trademark registrations significantly predate the registration date of the disputed domain names. In this regard, previous panels have established that knowledge of the Complainant’s trademarks, at the time of registration of the disputed domain names, proves bad faith registration. See for example Carrefour SA v. packet emblazer, WIPO Case No. D2024-4675: “In the present case, the Panel notes that given the widespread and longstanding use of the Complainant’s mark the same enjoys reputation. Previous UDRP panels have also acknowledged the Complainant’s reputation[...] Moreover, a simple Internet search reveals that the CARREFOUR mark is uniquely associated with the Complainant. Accordingly, the Panel concludes that the Respondent knew or at least should have known the CARREFOUR mark when it registered the disputed domain name.” The Complainant requests that the disputed domain names be transferred to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant must prove each of the following three elements: i. the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; 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.
page 4 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 Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel finds the mark is recognisable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms here, “-mall”, 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 mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. Accordingly, the Panel finds that the first element of the Policy has been satisfied. 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 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 3.0, section 2.1. The Complainant has made a prima facie case showing that the Respondent lacks rights or legitimate interests in the disputed domain names. The Complainant has not authorised, licensed, or otherwise permitted the Respondent to use its CARREFOUR trademark. There is no evidence that the Respondent is commonly known by the disputed domain names. Trademark searches conducted by the Complainant confirm that the Respondent does not own any trademark rights in CARREFOUR or similar terms. Furthermore, there is no evidence of any bona fide offering of goods or services or legitimate noncommercial or fair use of the disputed domain names. The current non-use of the disputed domain names, which resolve to error pages, does not constitute a bona fide offering of goods or services under the circumstances of the case. Moreover, the prior use of at least two of the disputed domain names ( and ) to resolve to websites featuring the Complainant’s logo and trademark and store images, along with buttons labelled “Recharge”, “App”, “Withdraw”, and “Company Profile”, appears to be as an attempt by the Respondent to impersonate the Complainant, and pass off as the Complainant’s official website, cannot confer rights or legitimate interests upon the Respondent. Panels have held that the use of a domain name for illegal activity, including claimed impersonation/passing off the Complainant, can never confer rights or legitimate interests on a respondent. See WIPO Overview 3.0, section 2.13.1.
page 5 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 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. The Panel finds that the Respondent has no rights or legitimate interests in respect of the disputed domain names, and the second element of the Policy has been satisfied. C. Registered and Used in Bad Faith Given the fame and renown of the CARREFOUR trademark, which has been registered and used worldwide since 1968, and the fact that the disputed domain names were registered on August 16, 2025, the Panel finds that the Respondent knew or should have known of the Complainant’s trademark rights at the time of registration. The Complainant’s trademark registrations significantly predate the registration date of the disputed domain names, and the Complainant and its CARREFOUR mark are so widely known that it is inconceivable the Respondent ignored the Complainant or its earlier rights in the CARREFOUR mark. Several prior UDRP decisions have recognised that the CARREFOUR trademark is well-known. The registration of disputed domain names that are confusingly similar to a well-known trademark, in the absence of any plausible good faith explanation, constitutes bad faith registration. With respect to bad faith use, the evidence demonstrates both passive holding and prior active impersonation. The historical use of at least two of the disputed domain names ( and ), as presented in the Complaint, to resolve to websites featuring the Complainant’s logo and trademark, store images, and buttons labelled “Recharge”, “App”, “Withdraw”, and “Company Profile”, was clearly designed to attract Internet users by creating confusion with the Complainant’s mark. According to paragraph 4(b)(iv) of the Policy, by using the disputed domain names, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a false association, likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the website. This is indicative of bad faith use under paragraph 4(b)(iv) of the Policy. The use of a privacy service to conceal the Respondent’s identity further supports a finding of bad faith. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. The Panel finds that the doctrine of passive holding applies in this case. Even though the disputed domain names currently resolve to error pages, 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. In this regard, the Panel has considered the following factors: - The distinctiveness and renown of the Complainant’s CARREFOUR trademark; - The Respondent’s failure to submit a Response or provide any evidence of actual or contemplated good faith use; - The prior use of at least two of the disputed domain names for impersonation; - The implausibility of any good faith use to which the disputed domain names may be put; and - The Respondent’s provision of incomplete or false contact details to conceal the Respondent’s identity. Accordingly, the Panel finds that the third element of the Policy has been satisfied.
page 6 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. /Munir Suboh/ Munir Suboh Sole Panelist Date: November 27, 2025
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