Carrefour v. Multiple Respondents: A Strategic URS Win Through Consolidation

By Francesca A. Rospenio

In this URS case, MFSD administered a dispute brought by Carrefour AS concerning a cluster of nine domain names that imitated the well-known CARREFOUR trademark through minor misspellings combined with the element “sa”. The domains—registered across .online, .site, .store and .space—were created within days of one another and all resolved to error pages. No Response was filed.

Confusing Similarity

The Examiner found the domains to be confusingly similar to Carrefour’s long-standing international trademarks. Each name reproduced a recognisable version of the mark, with misspellings characteristic of typosquatting, and the addition of “sa” reinforced, rather than reduced, the association with the brand.

No Rights or Legitimate Interests

There was no evidence that the Respondents were commonly known by the disputed names, nor any sign of legitimate rights or bona fide use. The complete absence of content and the lack of any authorisation from Carrefour supported the finding that the Respondents possessed no legitimate interests.

Bad-Faith Registration and Use

The Examiner concluded that the pattern of registrations—spread over multiple TLDs, closely timed, and clearly targeting the same mark—demonstrated bad-faith conduct. Passive holding did not mitigate this; instead, it strengthened the inference that the registrations were opportunistic and disruptive.

A Key Procedural Point: Consolidation

A central feature of the case was the Examiner’s decision to allow consolidation. While the URS does not explicitly regulate this issue, the Examiner relied on the WIPO Overview 3.0, noting that consolidation is appropriate where:

• there is prima facie evidence of common control; and

• consolidation is fair and efficient.

The domains shared the same registrar, similar naming patterns, near-identical registration dates, and the same geographic address in Turkey. These indicators supported a strong inference of a single underlying operator. Consolidation allowed the Complainant to address all nine domains in one proceeding, increasing procedural efficiency and strengthening the overall evidential picture.

A Strategic Takeaway

This determination highlights how effective enforcement often begins with a careful online behavioural analysis of the registrant. Identifying patterns across WHOIS data, timing, naming conventions and DNS behaviour can transform an isolated infringement into a broader, consolidated action—leading to a more comprehensive remedy.

The case reinforces the value of combining strong trademark rights with forensic online investigation, enabling rights holders to neutralise multiple abusive registrations through a single, well-prepared complaint.

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About the Author

“Francesca A. Rospenio” is the pen name of an international analyst specialising in online enforcement, trademark protection and alternative dispute resolution in digital environments. Her work focuses on URS/UDRP case law, platform accountability, and emerging patterns of abusive domain-name registrations across global TLD ecosystems.

With a background in intellectual-property governance and cross-border dispute resolution, she examines how online behavioural evidence and registrant-profiling techniques shape effective brand-protection strategies. Her insights are regularly used by rights holders, ADR bodies and practitioners seeking to understand the evolving dynamics of cybersquatting and domain-name abuse.