2. Author name: William Leibzon
a. e-mail: william at elan.net
b. telephone: 206-600-4982 (voice-mail pager only)
c. organization: Elan Networks
3. Proposal Version: 1.0
4. Submission Date: 08-20-04
5. Proposal type: modify
6. Policy term: permanent
7. Policy statement:
An organization with downstream residential customer who is not engaged
in business activities may substitute that organization's name for the
customer's name, e.g. 'Private customer - XYZ Network', and the
customer's street address may read 'Private Residence'. Each private
downstream residential reassignment must be less then or equal to 128 ips
and have accurate upstream Abuse and Technical POCs visible on the WHOIS
record for that block.
The intent of residential customer privacy was to allow private citizens
to have privacy and safety in their personal life while being able to
request and use more then 8 ip addresses with residenial dsl line.
However soon after implementation it became clear that some of the ip
blocks being designated as "Private customer" are being used for business
purposes which is clearly seen by size of such reassignments as
18.104.22.168/22. While it is not unexpected that some people may run
business (including internet businesses) from their home, the laws regard
such activity as being similar to running business from small office
and usually require such businesses to receive a license from appropriate
local or state agency and to disclose the activity to the public, as such
different privacy rules apply in these situations.
This policy replaces current residential customer privacy 2003-3 and
requires that ISPs only designate reassignment whois data as "Private
Customer" if no business activity is involved with use of the ip block.
The limit for the reassignment is set to 128 ips as larger number of
computers in one residence is likely an indication of business activity
(as an example currently telephone companies allow up to 4 residential
telephone lines and if somebody needs larger number of telephone lines
to his home, those must be purchased as business telephone lines).
Additionally the amendment fixes small grammer error in current policy
text that involves incorrect use of plural and singular tenses.
9. Timetable for implementation: 30 days or less after approval by BoT
10. Meeting presenter: to be designated by ARIN staff or by ARIN AC (policy
author most likely will be enable to come to next ARIN meeting).
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