Carrefour SA v Halsey Dixon, beijing shuai shuai, khiem khiem, vuvan van

WIPO Case No. D2025-3377

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Carrefour SA v. Halsey Dixon, beijing shuai shuai, khiem khiem, vuvan van,
yareli freddie, Hay Moi, Lnidn Kaiii, Willene Boyle

Case No. D2025-3377

1. The Parties

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

The Respondents are Halsey Dixon, United States of America (“United States”), beijing shuai shuai, United States, khiem khiem, United States, vuvan van, United States, yareli freddie, United States, Hay Moi, United States, and Lnidn Kaiii, Willene Boyle, China.

2. The Domain Names and Registrars

The disputed domain names <carrefoureg.shop>, <carrefoureg.store>, <carrefourkuwaite.com> and

<carrefourkuwait.store> are registered with Hostinger Operations, UAB.

The disputed domain names <carrefouregyipt.help> and <carrefourms.com> are registered with NameSilo,

LLC.

The disputed domain name <carrefouruae.pro> is registered with Dynadot Inc (the “Registrars”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 22, 2025. On August 22, 2025, the Center transmitted by email to the Registrars a request for registrar verification in connection with the disputed domain names. On August 22 and 25, 2025, the Registrars transmitted by email to the Center their verification responses disclosing registrant and contact information for the disputed domain names which differed from the named Respondents (Unknown, Domain Admin, Privacy Protect, LLC (PrivacyProtect.org) / Domain Administrator, PrivacyGuardian.org / 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 August 27, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaints 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 August 27, 2025.

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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 September 2, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 22, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on September 24, 2025.

The Center appointed Zoltán Takács as the sole panelist in this matter on September 26, 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 worldwide leaders in retail and one of the first creators of the hypermarket concept back in 1968.

With the revenue of EUR 84,9 billion in 2023, the Complainant is listed on the Paris Stock Exchange (CAC
40) index and operates more than 14,000 stores in over 40 countries.

The Complainant was introduced to the Middle East region in 1995 by United Arab Emirates (the “UAE”) based company called Majid Al Futtaim (MAF), which owns exclusive rights to operate CARREFOUR stores under its distinct name and “M” logo throughout the region, including among others in the UAE, Egypt, and Kuwait.

The Complainant owns numerous trademark registrations around the world for the mark CARREFOUR, by way of example the International Trademark Registration No. 351147 registered on October 2, 1968.

The Complainant maintains its global online presence through its principal website “ with the corresponding domain name being registered since October 25, 1995.

There are also e-commerce websites for, among others, Egypt (“ with the corresponding domain name being registered since July 31, 2000), UAE (“ with the corresponding domain name being registered since July 29, 2000), and Kuwait (“ with the corresponding domain name being registered since July 31, 2000).

The disputed domain names were registered between July 22 and August 16, 2025.

At the time of filing of the Complainant the disputed domain name <carrefourms.com> resolved to an online store website which resembled the Complainant’s official website “ reproducing the Complainant’s trademark, the MAF’s name and its signature “M” logo. The remaining six disputed domain names resolved to blank or error pages.

According to the evidence submitted by the Complaint, prior to the filing of the Complaint the disputed
domain names <carrefoureg.shop> and <carrefouruae.pro> also resolved to websites that displayed the

Complainant’s trademark and the MAF’s name and signature “M” logo.

Currently all the disputed domain names resolve to blank or error pages.

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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 which incorporate its well-known trademark with the addition of country names

and abbreviations corresponding to the Middle East region are confusingly similar to the trademark;

- the Respondents have no rights or legitimate interests in respect of the disputed domain names since they

are unable to rely on any of the circumstances set out in paragraphs 4(c)(i), (ii), or (iii) of the Policy;

- given the global fame of the Complainant’s trademark the Respondents must have had it in mind at

registration of the disputed domain names;

- the Respondents used the dispute domain names <carrefourms.com>, <carrefoureg.shop>, and
<carrefouruae.pro> to benefit from the fame of the Complainant and its trademark to make a commercial

gain by creating a likelihood of confusion with the Complainant’s trademark; and

- the Respondents concealed their identities through use of contact details that are fanciful at best which is

indication of bad faith.

The Complainant requests that the disputed domain names be transferred from the Respondents to the

Complainant.

B. Respondents

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

6. Discussion and Findings

In order to succeed on a complaint, a complainant must evidence each of the three elements required by paragraph 4(a) of the Policy, namely that:

(i) the domain name 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 domain name; and

(iii) the domain name have been registered and are being used in bad faith.

6.1. Preliminary Matters – Consolidation: Multiple Respondents

The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name 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 name registrants pursuant to paragraph 10(e) of the Rules.

The disputed domain name registrants did not comment on the Complainant’s request.

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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 that: (i) the disputed domain names were registered within relatively short period of time; (ii) the disputed domain names incorporate the Complainant’s trademark plus various terms; (iii) the registrants’ contact details provided by the Registrars at the request of the Center appear to be fanciful and meaningless and show some similarities; (iv) the disputed domain names <carrefoureg.shop>, <carrefoureg.store>, and <carrefourkuwaite.com> although registered by nominally different registrants share the same physical address, and (v) the disputed domain names <carrefourms.com>, <carrefoureg.shop>, and <carrefouruae.pro> although registered by nominally different registrants resolved to similar online store websites that displayed the Complainant’s trademark and the MAF’s name and signature “M” logo.

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 name registrants (referred to below as “the Respondent”) in a single proceeding.

6.2. Substantive Matters

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 names. WIPO Overview 3.0, section 1.7.

The disputed domain names contain the Complainant’s CARREFOUR trademark which is recognizable within the disputed domain names. The addition of the terms “eg” (the abbreviation for Egypt), “egyipt” (misspelling of Egypt), “kuwaite” (misspelling of Kuwait), “kuwait”, “ms”, and “uae” (the abbreviation for United Arab Emirates) to the Complainant’s trademark in the disputed domain names does not prevent a

finding of confusing similarity between the disputed domain names and the trademark for the purposes of the

Policy. WIPO Overview 3.0, sections 1.7 and 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 the disputed domain names.

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.

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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 Complainant has submitted sufficient and uncontested evidence that it holds well-established prior rights in the CARREFOUR trademark. The Complainant has never authorized the Respondent to use its trademark, in the disputed domain names or otherwise.

The disputed domain names <carrefourms.com>, <carrefoureg.shop>, and <carrefouruae.pro> were used in relation to online store websites which reproduced the Complainant’s trademark and the MAF’s name and signature “M” logo. Given the confusing similarity between these disputed domain names and the Complainant’s trademark, the absence of any relationship between the Respondent and the Complainant and the risk of implied affiliation with the Complainant the Respondent’s use of these disputed domain names to trade of the goodwill and reputation of the Complainant is not a bona fide use or a legitimate noncommercial or fair use.

The other four disputed domain names resolved to inactive pages. The Respondent’s use of these disputed domain names to resolve to blank pages lacking content or displaying error messages is not evidence of a bona fide offering of goods or services under the Policy.

The Panel finds that 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.

Having reviewed the record, the Panel finds that the Respondent’s registration and use of the disputed domain names constitutes bad faith under the Policy.

D2015-0962). UDRP panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4.

The Panel notes that prior decisions under the UDRP established the global well-known status of the WIPO Case No.

In view of the Panel, it is implausible that the Respondent did not have the Complainant’s trademark in mind at registration of the disputed domain names.

Noting the above, coupled also with the use to which the disputed domain names <carrefourms.com>,
<carrefoureg.shop>, and <carrefouruae.pro> have been put the Panel finds that the Respondent has
registered and used the disputed domain names with the Complainant’s rights in mind intending to create a
likelihood of confusion and trade of the goodwill associated with the well-known CARREFOUR trademark.
Such targeting is evidence of bad faith. WIPO Overview 3.0, section 3.2.1.

Furthermore, the Panel agrees with UDRP decisions which found that a deliberate concealment of identity and contact information may be a further indication of registration in bad faith. See TTT Moneycorp Limited v. Diverse Communications, WIPO Case No. D2001-0725. In the present case the Respondent registered the disputed domain names with fanciful contact details, which suggests that the Respondent was taking steps to shield its true identity. WIPO Overview 3.0, section 3.6.

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As for the current, effectively inactive status of the disputed domain names, the Panel finds that it does not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. In this context the Panel notes the degree of distinctiveness and global fame of the Complainant’s trademark, the composition of the disputed domain names and the previous use of the disputed domain names <carrefourms.com>, <carrefoureg.shop>, and <carrefouruae.pro>, and the Respondent’s provision of fanciful contact details, and finds that in the circumstances of this case the current passive holding of the disputed domain names 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 names <carrefoureg.shop>, <carrefoureg.store>, <carrefouregyipt.help>, <carrefourkuwaite.com>, <carrefourkuwait.store>, <carrefourms.com>, and <carrefouruae.pro> be

transferred to the Complainant.

/Zoltán Takács/
Zoltán Takács
Sole Panelist
Date: October 9, 2025