Carrefour SA v abnormal handheld

WIPO Case No. D2025-2647

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Carrefour SA v. abnormal handheld

Case No. D2025-2647

1. The Parties

The Complainant is Carrefour SA, France, represented by IP Twins, France.

The Respondent is abnormal handheld, United States of America (“United States”).

2. The Domain Name and Registrar

The disputed domain name <carrefour-login.com> is registered with Sav.com, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 7, 2025. On July 7, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 24, 2025, the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the disputed domain name which dif fered f rom the named Respondent (REDACTED FOR PRIVACY) and contact information in the

Complaint. The Center sent an email communication to the Complainant on July 24, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on July 25, 2025.

The Center verif ied that the Complaint together with the amended Complaint satisf ied 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 notif ied the Respondent of the Complaint, and the proceedings commenced on July 25, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 14, 2025. The Respondent did not submit any response.

Accordingly, the Center notif ied the Respondent’s default on August 15, 2025.

The Center appointed Petra Pecar as the sole panelist in this matter on August 19, 2025. The Panel f inds 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.

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4. Factual Background

The Complainant is Carrefour SA, a global leader in retail and pioneer of the hypermarket concept since 1968. Listed on the Paris Stock Exchange (CAC 40), it operates over 14,000 stores in more than 40 countries, employs over 500,000 people, and reported revenues of EUR 84.9 billion in 2023. In addition to retail, the Complainant of fers services in travel, banking, insurance and ticketing.

The Complainant is the owner of several CARREFOUR marks registered worldwide, including the following:

- International word trademark CARREFOUR Reg. No. 351147, registered on October 2, 1968 in
Classes 1 to 34 in several countries;

- International word service mark CARREFOUR Reg. No. 353849, registered on February 28, 1969 in
Classes 35 to 42 in several countries; and

- European Union word mark CARREFOUR Reg. No. 5178371, registered on August 30, 2007 in
Classes 9, 35 and 38.

The Complainant owns numerous domain names identical to, or comprising, its CARREFOUR marks, including <carrefour.com>, <carrefour.fr>, <carrefour.com.br>, <carrefouruae.com>, <carrefourqatar.com>, <carrefourmarket.f r>, <carrefour-banque.f r>, <carrefourbanca.it>, <carrefourf inance.be>, and

<carrefour.sn>.

The disputed domain name was registered on June 23, 2025 and at the time of the Complaint f iling it resolved to an inactive webpage.

The Respondent is located in United States.

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 its earlier CARREFOUR marks are well-known, distinctive, and enjoy a strong international reputation and recognition, as consistently conf irmed in numerous panel decisions. The Complainant’s fame and notoriety is further evidenced on the Internet, with its Facebook page alone being followed by more than 11 million users.

The Complainant asserts that the disputed domain name is confusingly similar to its well-known
CARREFOUR marks, as it reproduces the CARREFOUR mark in full of the mere addition of the generic term
“login”. The Complainant states that adding such terms does not dispel confusion, and that numerous
panels decisions established that full incorporation of a trademark suffices to show confusing similarity. The
“.com” extension is not signif icant in determining whether the disputed domain name is identical or
confusingly similar to the trademarks of the Complainant.

The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent owns no trademark rights, is not commonly known by the disputed domain name, and received no authorization to use the Complainant’s CARREFOUR marks. The disputed domain name resolves to an inactive webpage with a malicious warning and cannot constitute bona f ide use.

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The Complainant submits that the Respondent registered the disputed domain name in bad faith, contending that the circumstances support a f inding that the Complainant’s well-known CARREFOUR marks and longstanding reputation were known to the Respondent at the time of registration. The choice of disputed domain name appears intentional to exploit the Complainant’s reputation, divert users, and create a misleading impression of association with the Complainant. Since the Complainant’s rights predate disputed domain name registration, and the disputed domain name is either passively held or linked to harmful use, such conduct cannot be considered legitimate or in good faith.

The Complainant contends that the Respondent’s concealed identity, maintained through false contact details, constitutes evidence of bad faith.

B. Respondent

The Respondent did not reply to the Complainant’s contentions.

6. Discussion and Findings

Even if the Respondent did not file a Response to the Complainant’s contentions, the Panel shall consider the issues present in the case based on the statements and documents submitted by the Complainant.

“A Panel shall decide a complaint on the basis of the statements and documents submitted and in
accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”, as
indicated in paragraph 15(a) of the Rules.

Under paragraph 4(a) of the Policy, the Complainant is required to prove each of the following three elements:

(i) the disputed domain name is 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 name; and

(iii) the disputed domain name has been registered and is being used by the Respondent in bad faith.

A. Identical or Confusingly Similar

It is well accepted that the f irst 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 mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.

The entirety of the CARREFOUR 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 3.0, section 1.7.

Although the addition of a hyphen and term “login”, which is descriptive and may suggest an of f icial sign-in webpage, may bear on assessment of the second and third elements, the Panel f inds 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.

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Furthermore, it is well accepted practice by UDRP panels that a generic Top-Level Domain (“gTLD”), such as “.com”, is typically ignored when assessing whether a domain name is identical or confusingly similar to a trademark (see section 1.11.1 of the WIPO Overview 3.0). For that reason, the Panel accepts not to take into consideration the gTLD “.com” when assessing confusing similarity of the disputed domain name.

The Panel f inds the f irst 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 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 of ten 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 satisf ied the second element. WIPO Overview 3.0, 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.

According to the Complainant, it appears that the Respondent is not af f iliated or connected with the Complainant in any manner, nor has the Complainant granted the Respondent any license or authorization to use or register a domain name incorporating the Complainant’s CARREFOUR marks. The Respondent has also failed to respond to the Complaint, thereby failing to provide any information or factors that could potentially establish prior rights or legitimate interests in the disputed domain name. Furthermore, there is no evidence indicating that the Respondent has engaged in any legitimate or bona f ide use of the disputed domain name, either for commercial or noncommercial purposes, as the disputed domain name, at the time the Complaint was filed, resolved to an inactive webpage showing a “404” notice stating “the site you are trying to reach was potentially malicious and is no longer online”. Passive holding in these circumstances does not establish rights or legitimate interests.

The Panel f inds 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.

In the present case, the Panel observes that the Respondent’s disputed domain name consists of a combination of the CARREFOUR marks, a hyphen, the additional element “login”, and the gTLD “.com”. The inclusion of “login” functions as a descriptive reference to one of the Complainant’s business, denoting the common process of accessing or signing into an online system rather than indicating any distinctive source of goods or services. Having regard to the longstanding and well-known CARREFOUR marks, which predate the disputed domain name registration by 57 years, and to the targeting implied by the descriptive term “login”, the incorporation of the CARREFOUR marks in its entirety supports the f inding that the Respondent registered the disputed domain name with knowledge of the Complainant and its CARREFOUR

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marks. The composition of the disputed domain name, pairing the CARREFOUR marks with the descriptive
“login” element, gives rise to a misleading association with the Complainant and its online services.
Accordingly, the Panel concludes that the disputed domain name was registered in bad faith.

Panels have found that the non-use of a domain name (including an error webpage) would not prevent a f inding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s CARREFOUR trademark, and the composition of the disputed domain name, and f inds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a f inding of bad faith under the Policy.

The Panel f inds 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-login.com> be transferred to the Complainant.

/Petra Pecar/
Petra Pecar
Sole Panelist
Date: August 27, 2025