French blocking order: DNS resolvers, VPNs, search engines

On 17 July 2026 Irène Benac, vice-president of the Tribunal judiciaire de Paris, signed fourteen orders — RG 26/08356 through RG 26/08401 — requiring 73 domains to be blocked on Canal+‘s application under Article L. 333-10 of the Code du sport, 47 for Premier League streams and 26 for the Champions League. The Premier League blocks run from 22 August 2026 to 30 May 2027, the Champions League set to 5 June 2027, and both are dynamic: new domains are added through the season with ARCOM’s approval. What is unusual is the respondent list. Beside Orange, Free, SFR and Bouygues Telecom — plus SPM, Telco OI, UTS Caraïbe and Zeop overseas — the orders reach Cloudflare as DNS, CDN and proxy; the public resolvers Google Public DNS, Quad9 and DNS4EU (Whalebone); the VPN operators Proton VPN, CyberGhost and ExpressVPN; and Google Search and Bing for de-referencing.

They were contested and they lost. CyberGhost and ExpressVPN asked for a stay pending a reference to the CJEU, leaning on Anne Frank Stichting, and argued that L. 333-10 cannot stand against the e-Commerce Directive. The court declined both: Anne Frank concerned a different directive and a publication that was itself lawful, and a directive has no horizontal direct effect, so a national statute is not disapplied in a dispute between private companies. On the substance the court held that even though an intermediary may act passively and neutrally, it can still be an essential link in transferring infringing data — the mere act of serving as a bridge enabling access to the infringing sites fulfils the transmission function. Quad9 and Whalebone defaulted. Google contested the DNS and search orders and lost.

Why it matters

The perimeter of “intermediary” has moved. It is no longer the access provider at the edge; it is anyone on the resolution path — recursive resolver, reverse proxy, VPN exit, search index. That is precisely the set of layers a clone or impersonation operator relies on to survive a domain-level takedown, and a court of first instance in a major EU jurisdiction has now said that neutrality at those layers is not an answer to an injunction.

Counsel’s note

Ihor Makushinsky · senior counsel

Read the reasoning, not the remedy. The finding that matters is that passive, neutral conduct does not exempt an intermediary from an order — it only means the intermediary is not liable in damages. Those are different questions, and operators of clone infrastructure have spent years conflating them in abuse responses. This order is a citable answer.

Now the honest limit. L. 333-10 is a sports-broadcasting statute: standing belongs to professional leagues and companies holding exclusive audiovisual rights to sporting events. A casino, broker, prop firm or game studio cannot file under it, and any vendor telling you this order is a template for your clone problem has not read the first page. The French doors that are open to a brand owner are Article L. 716-4-6 CPI, which lets a trademark owner seek interim measures in référé against the infringer or the intermediaries whose services they use, and the general LCEN route the Paris court used for Richemont in January 2020 to block counterfeit sites at ISP level. Both reach intermediaries. Neither has yet been stretched to a VPN.

Which is where the evidentiary work sits. The court did not block a resolver because a resolver exists; it blocked because the resolver was shown to be an essential link in access from French territory. If you want a resolver, proxy or VPN named in an operative part, you have to prove that path — resolution records, redirect chains, the traffic actually arriving from the market you are protecting. A list of domains does not get you there.

One thing to watch: the French sports law adopted on 21 July 2026 is reported to move ARCOM from approving dynamic additions in advance to reviewing them afterwards. Pre-clearance is the friction that makes dynamic blocking slow. If it goes, the dynamic list — not the original order — becomes the operative instrument, and the standard of proof behind each addition becomes the only control left.

What this means for you

If clones or mirrors are your problem, choose the jurisdiction where your traffic is, then build the record that names each intermediary’s role in reaching it — before you plead. Our guides on taking down a casino clone and finding the real host behind Cloudflare cover the groundwork, and our operators page sets out how we run the monitoring that catches the replacement domain.