From info at arin.net  Mon Oct  5 16:27:15 2009
From: info at arin.net (Member Services)
Date: Mon, 05 Oct 2009 16:27:15 -0400
Subject: [ARIN-consult] =?windows-1252?q?Call_for_Community_Consultation_?=
 =?windows-1252?q?=96ARIN_Resource_Revocation_Procedures?=
Message-ID: <4ACA56A3.90800@arin.net>

ARIN is seeking community input regarding potential changes to ARIN?s 
number resource revocation procedures.  

ARIN initiates the revocation process when an organization is more than 
90 days overdue on their registration fees.  After every possible 
attempt has been made to contact the organization, ARIN will revoke the 
resource(s) and remove the record from the database.  At that time, the 
resource is put into a ?hold bucket? for one year before it is added 
into the available pool for re-issue.  This 12-month period allows 
adequate time for the resource to clear any filters, and also allows 
ample time for the organization to pay the overdue fees.

ARIN currently allows organizations the full 12-month period to pay 
overdue fees and have resources reinstated.  It has been our experience 
that the majority of ISP and end-user organizations pay overdue fees 
within one week of having resources revoked, but ASN registrants, who 
often don?t feel an immediate operational impact from of the revocation, 
tend to come back to pay long after the revocation occurs.  

To align our procedures with more generally accepted business practices, 
ARIN is considering reducing the amount of time an organization has to 
pay overdue fees to six months, at which point, if no payment has been 
made, the resources would be permanently revoked.  If an organization 
attempts to submit payment after the six month limit, they would be 
required to reapply. If approved, they could receive the same resources 
if they are available, or new ones if not.  

ARIN is seeking comments regarding this proposed change through the ARIN 
Consultation and Suggestion Process, available at:
https://www.arin.net/participate/acsp/index.html

Discussion on arin-consult at arin.net will close on 6 November 2009, at 
noon EDT.

We welcome community-wide participation. Please address any process 
questions to info at arin.net.

Regards,

Member Services
American Registry for Internet Numbers (ARIN)







From jambu at honelive.com  Mon Oct  5 17:06:37 2009
From: jambu at honelive.com (Anantha Jambu)
Date: Mon, 05 Oct 2009 17:06:37 -0400
Subject: [ARIN-consult]
 =?utf-8?q?=5Barin-announce=5D_Call_for_Community_C?=
 =?utf-8?q?onsultation_=E2=80=93ARIN_Resource_Revocation_Procedures?=
In-Reply-To: <4ACA5659.1040407@arin.net>
References: <4ACA5659.1040407@arin.net>
Message-ID: <1254776797.5135.34.camel@Leroy2.interserver.net>

Well...it makes sense to revoke completely after 6 months but keep
revoked space at the bottom of the reuse pool.

And if the organization comes after 6 months for their revoked space,
charge the regular renewal fee and on top of that a penalty fee.

So 90 days Warning.
Suspend until 180 days then revoke.
Ability to retrieve with a FEE until 365 days.

-----Original Message-----
From: Member Services <info at arin.net>
To: arin-announce at arin.net
Subject: [arin-announce] Call for Community Consultation ?ARIN Resource
Revocation Procedures
Date: Mon, 05 Oct 2009 16:26:01 -0400

ARIN is seeking community input regarding potential changes to ARIN?s 
number resource revocation procedures.  

ARIN initiates the revocation process when an organization is more than 
90 days overdue on their registration fees.  After every possible 
attempt has been made to contact the organization, ARIN will revoke the 
resource(s) and remove the record from the database.  At that time, the 
resource is put into a ?hold bucket? for one year before it is added 
into the available pool for re-issue.  This 12-month period allows 
adequate time for the resource to clear any filters, and also allows 
ample time for the organization to pay the overdue fees.

ARIN currently allows organizations the full 12-month period to pay 
overdue fees and have resources reinstated.  It has been our experience 
that the majority of ISP and end-user organizations pay overdue fees 
within one week of having resources revoked, but ASN registrants, who 
often don?t feel an immediate operational impact from of the revocation, 
tend to come back to pay long after the revocation occurs.  

To align our procedures with more generally accepted business practices, 
ARIN is considering reducing the amount of time an organization has to 
pay overdue fees to six months, at which point, if no payment has been 
made, the resources would be permanently revoked.  If an organization 
attempts to submit payment after the six month limit, they would be 
required to reapply. If approved, they could receive the same resources 
if they are available, or new ones if not.  

ARIN is seeking comments regarding this proposed change through the ARIN 
Consultation and Suggestion Process, available at:
https://www.arin.net/participate/acsp/index.html

Please submit your comments to the arin-consult at arin.net. You can 
subscribe to the arin-consult mailing list at:
http://lists.arin.net/mailman/listinfo/arin-consult

Discussion on arin-consult at arin.net will close on 6 November 2009, at 
noon EDT.

We welcome community-wide participation. Please address any process 
questions to info at arin.net.

Regards,

Member Services
American Registry for Internet Numbers (ARIN)





_______________________________________________
ARIN-Announce
You are receiving this message because you are subscribed to
the ARIN Announce Mailing List (ARIN-announce at arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-announce
Please contact info at arin.net if you experience any issues.
-- 

Thanks,
Anantha Jambu



From michael.dillon at bt.com  Mon Oct  5 18:19:21 2009
From: michael.dillon at bt.com (michael.dillon at bt.com)
Date: Mon, 5 Oct 2009 23:19:21 +0100
Subject: [ARIN-consult] [arin-announce] Call for Community Consultation
	-ARIN Resource Revocation Procedures
In-Reply-To: <1254776797.5135.34.camel@Leroy2.interserver.net>
Message-ID: <28E139F46D45AF49A31950F88C49745803695C64@E03MVZ2-UKDY.domain1.systemhost.net>


> And if the organization comes after 6 months for their 
> revoked space, charge the regular renewal fee and on top of 
> that a penalty fee.
> 
> So 90 days Warning.
> Suspend until 180 days then revoke.
> Ability to retrieve with a FEE until 365 days.

Any penalties and conditions should be clearly stated on the
invoice, not in fine print but clearly stated.

Currently the invoices have *NOTHING* about any of this,
not even mentioning the possibility of revocation for non-payment.
Instead they have far too much text about method of payment which
leads me to believe that the invoice has been designed by ARIN's
billing department.

Going forward, the BoT needs to set some standards for what is
on the invoices, and any revocation process and penalty charges
must be clearly stated right on the invoice.

In larger companies, the people who look after IP addresses
often have no direct contact at all with the payables department,
and instead rely on tortuous processes to forward the invoice 
through several people to get it paid at all.

However, accounts payable departments do pay very close attention
to the details written on the invoice, and do act on them. Woe betide
those who submit an ARIN invoice that has no P.O. number on it. The 
payables department doesn't care that you mentioned the P.O. number 
in email, and may never even see your email due to the tortuous route
mentioned above.

--Michael Dillon

P.S. How about a process to issue an email notice, one month before
the invoice is issued, and sent to the admin POC, informing them that
an invoice will be issued on such and such a date, and if they
want a PO number to be quoted please send it in before said date. 
And also explain the full terms of the revocation policy and penalties.

This would cost ARIN next to nothing, and keep people informed
who are not the billing POC. 


From owen at delong.com  Mon Oct  5 19:16:57 2009
From: owen at delong.com (Owen DeLong)
Date: Mon, 5 Oct 2009 16:16:57 -0700
Subject: [ARIN-consult] ARIN Resource Revocation Procedures
Message-ID: <5402FEC7-6F2F-49CD-A540-C8DCA3ABA9FF@delong.com>

I support reducing the timeframe to 6 months.

I would also support requiring a re-application on a shorter time- 
frame than the resources re
released into the free pool, for example, if you are delinquent for 3  
months, you can pay and
re-apply, but, you are guaranteed (if your reapplication is  
successful) to get your original
resources.  After 6 months, you only get your resources if they are  
available and they may not
be.

Owen



From info at arin.net  Tue Oct  6 16:23:50 2009
From: info at arin.net (Member Services)
Date: Tue, 06 Oct 2009 16:23:50 -0400
Subject: [ARIN-consult] =?windows-1252?q?Call_for_Community_Consultation_?=
 =?windows-1252?q?=96_Changes_to_ARIN_RSS_Feed?=
Message-ID: <4ACBA756.8020708@arin.net>

ARIN is seeking community input about potential changes to the RSS feed 
that provides a daily report of address space returned to and issued by 
ARIN. ARIN wants to ensure the data in this RSS feed is provided in the 
manner most useful to the community.

To understand the data currently provided in this RSS feed, it is 
important to define the terminology used to describe the different ways 
number resources are recovered by ARIN. Revoked address space is space 
that ARIN takes back from a registrant for non-payment of registration 
fees. Reclaimed address space is space that ARIN takes back in response 
to confirmed fraudulent activity by the registrant or someone else (i.e. 
hijacking), OR because ARIN has found that the address space is not 
being used by the original registrant (out of business) and there is no 
evidence that the business was acquired or merged. Returned address 
space is space that is voluntarily returned to ARIN by the registrant 
because it is no longer in use and/or needed.

Each time that ARIN recovers an address block (regardless of the 
recovery method) it is placed into hold status for one year to allow 
adequate time to clear filters. Currently, this RSS feed is a daily 
e-mail update listing the recovered address space (without attribution 
to the recovery method) that has been released from hold status and is 
available for re-issue to a new customer. The RSS feed also lists all 
address space issued by ARIN that day.

Recently, there has been discussion by the community about:

1. Adding additional data to the RSS feed, including listing the address 
space recovered and put into hold status each day
2. Enhancing the current RSS feed format and associated report that goes 
out over a distribution only e-mail list using a XML format.

Please note that there may be some controversy associated with adding 
address space to the RSS feed on the day it is recovered by ARIN. Some 
individuals have expressed concern that advertising the date when space 
is recovered would give a heads up to the ?bad actors? and make the 
space a target for abuse.

ARIN welcomes your feedback on each of these topics and will use your 
input to determine our course of action.

The current process for subscribing to the RSS feed and additional 
information about it can be found at:

https://www.arin.net/participate/mailing_lists/rss.html

ARIN is seeking comments regarding this proposed change through the ARIN 
Consultation and Suggestion Process, available at:
https://www.arin.net/participate/acsp/index.html

Discussion on arin-consult at arin.net will close on 6 November 2009 at 
noon EDT.

We welcome community-wide participation. Please address any process 
questions to info at arin.net.

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


From bob at xa.net  Thu Oct  8 14:07:08 2009
From: bob at xa.net (Robert Keyes)
Date: Thu, 8 Oct 2009 14:07:08 -0400 (EDT)
Subject: [ARIN-consult] ARIN Resource Revocation Procedures
In-Reply-To: <5402FEC7-6F2F-49CD-A540-C8DCA3ABA9FF@delong.com>
References: <5402FEC7-6F2F-49CD-A540-C8DCA3ABA9FF@delong.com>
Message-ID: <Pine.LNX.4.64.0910081400350.14552@neptune.sinister.com>

I think that there should be some sort of differentiation between 
'abandoned' resources and resources that an entity wants to keep but is 
having trouble paying the fees for. In this economic recession, many 
organisations are suffering, having trouble paying salaries, and it would 
be a shame to push them into insolvency faster than is needed.

On Mon, 5 Oct 2009, Owen DeLong wrote:

> I support reducing the timeframe to 6 months.
>
> I would also support requiring a re-application on a shorter time-frame than 
> the resources re
> released into the free pool, for example, if you are delinquent for 3 months, 
> you can pay and
> re-apply, but, you are guaranteed (if your reapplication is successful) to 
> get your original
> resources.  After 6 months, you only get your resources if they are available 
> and they may not
> be.
>
> Owen
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN Consult 
> Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN 
> Member Services
> Help Desk at info at arin.net if you experience any issues.
>


From sethm at rollernet.us  Thu Oct  8 14:56:03 2009
From: sethm at rollernet.us (Seth Mattinen)
Date: Thu, 08 Oct 2009 11:56:03 -0700
Subject: [ARIN-consult] ARIN Resource Revocation Procedures
In-Reply-To: <Pine.LNX.4.64.0910081400350.14552@neptune.sinister.com>
References: <5402FEC7-6F2F-49CD-A540-C8DCA3ABA9FF@delong.com>
	<Pine.LNX.4.64.0910081400350.14552@neptune.sinister.com>
Message-ID: <4ACE35C3.9050501@rollernet.us>

Robert Keyes wrote:
> I think that there should be some sort of differentiation between
> 'abandoned' resources and resources that an entity wants to keep but is
> having trouble paying the fees for. In this economic recession, many
> organisations are suffering, having trouble paying salaries, and it
> would be a shame to push them into insolvency faster than is needed.
> 

It should not be ARIN's job to decide who doesn't need to pay their fees
on time and who does.

~Seth


From SRyan at mwe.com  Thu Oct  8 15:10:43 2009
From: SRyan at mwe.com (Ryan, Stephen)
Date: Thu, 8 Oct 2009 14:10:43 -0500
Subject: [ARIN-consult] ARIN Resource Revocation Procedures
In-Reply-To: <Pine.LNX.4.64.0910081400350.14552@neptune.sinister.com>
References: <5402FEC7-6F2F-49CD-A540-C8DCA3ABA9FF@delong.com>
	<Pine.LNX.4.64.0910081400350.14552@neptune.sinister.com>
Message-ID: <DF8B3819D464D9428392AE8E75A56ED3B8A38F422E@LISEVS01.na.lan.mwe.com>

The amount of money owed or paid to ARIN will not likely be the cause of  a bankruptcy, since the fees to ARIN are very modest. ARIN's experience is it gets paid when it revokes.  In recent times, ARIN has not pursued to a judgement and then reported to bankruptcy court as one of the unresolved judgements.  ARIN could do so, and reserves the right to do so, but the small amount at issue makes that uneconomical in most instances.  Employee salaries,  rent,  etc. are where unpaid creditors are normally seeking judgements, and throwing folks into bankruptcy. But ARIN would put itself at the end of the line of creditors to be paid if it maintains too long a redemption policy before revocation.



Stephen M. Ryan
McDermott Will & Emery LLP
600 Thirteenth Street, N.W.
Washington, DC 20005-3096

sryan at mwe.com
(P) 202.756.8333
(F) 202.756.8087

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IRS Circular 230 Disclosure: To comply with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained herein (including any attachments), unless specifically stated otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter herein.
________________________________________________________________________________
This message is a PRIVATE communication. This message and all attachments are a private communication sent by a law firm and may be confidential or protected by privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained in or attached to this message is strictly prohibited. Please notify the sender of the delivery error by replying to this message, and then delete it from your system. Thank you.
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-----Original Message-----
From: arin-consult-bounces at arin.net [mailto:arin-consult-bounces at arin.net] On Behalf Of Robert Keyes
Sent: Thursday, October 08, 2009 2:07 PM
To: Owen DeLong
Cc: arin-consult at arin.net
Subject: Re: [ARIN-consult] ARIN Resource Revocation Procedures

I think that there should be some sort of differentiation between
'abandoned' resources and resources that an entity wants to keep but is
having trouble paying the fees for. In this economic recession, many
organisations are suffering, having trouble paying salaries, and it would
be a shame to push them into insolvency faster than is needed.

On Mon, 5 Oct 2009, Owen DeLong wrote:

> I support reducing the timeframe to 6 months.
>
> I would also support requiring a re-application on a shorter time-frame than
> the resources re
> released into the free pool, for example, if you are delinquent for 3 months,
> you can pay and
> re-apply, but, you are guaranteed (if your reapplication is successful) to
> get your original
> resources.  After 6 months, you only get your resources if they are available
> and they may not
> be.
>
> Owen
>
> _______________________________________________
> ARIN-Consult
> You are receiving this message because you are subscribed to the ARIN Consult
> Mailing
> List (ARIN-consult at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN
> Member Services
> Help Desk at info at arin.net if you experience any issues.
>
_______________________________________________
ARIN-Consult
You are receiving this message because you are subscribed to the ARIN Consult Mailing
List (ARIN-consult at arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services
Help Desk at info at arin.net if you experience any issues.

*******************************************************************************************************************
IRS Circular 230 Disclosure:  To comply with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained herein (including any attachments), unless specifically stated otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter herein.
________________________________________________________________________________

This message is a PRIVILEGED AND CONFIDENTIAL communication. This message and all attachments are a private communication sent by a law firm and may be confidential or protected by privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained in or attached to this message is strictly prohibited.  Please notify the sender of the delivery error by replying to this message, and then delete it from your system.  Thank you.
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Please visit http://www.mwe.com/ for more information about our Firm.


From michael.dillon at bt.com  Fri Oct  9 08:27:13 2009
From: michael.dillon at bt.com (michael.dillon at bt.com)
Date: Fri, 9 Oct 2009 13:27:13 +0100
Subject: [ARIN-consult] ARIN Resource Revocation Procedures
In-Reply-To: <Pine.LNX.4.64.0910081400350.14552@neptune.sinister.com>
Message-ID: <28E139F46D45AF49A31950F88C49745803805F96@E03MVZ2-UKDY.domain1.systemhost.net>

> I think that there should be some sort of differentiation 
> between 'abandoned' resources and resources that an entity 
> wants to keep but is having trouble paying the fees for. In 
> this economic recession, many organisations are suffering, 
> having trouble paying salaries, and it would be a shame to 
> push them into insolvency faster than is needed.

I agree. If a company is genuinely using the resources but
has difficulty paying for any reason, whether it is due
to awful internal payment approval processes or because 
they have cashflow problems, ARIN should offer them an
extended payment plan. 

I'm not sure how this is done in the USA, but back when
I was doing business in Canada, it was common for all
invoices to quote payment terms including a discount
for payment within x days (usually 10) and an interest
rate penalty for payments over y days (usually 30).

And of course, there are also negotiated payment plans
where you both agree that this is no longer a payment
issue, but that the amount outstanding is a loan and
there will be an agreed monthly minimum payment and
interest rate until it is paid off.

We can't put all the details in policy, but we could make
the distinction that Owen mentioned, and also state that
companies who agree to a payment plan could keep their 
resources. The details of the payment plans would then
be up to the BoT and to ARIN's finance department.

--Michael Dillon


From michael.dillon at bt.com  Fri Oct  9 08:32:04 2009
From: michael.dillon at bt.com (michael.dillon at bt.com)
Date: Fri, 9 Oct 2009 13:32:04 +0100
Subject: [ARIN-consult] ARIN Resource Revocation Procedures
In-Reply-To: <DF8B3819D464D9428392AE8E75A56ED3B8A38F422E@LISEVS01.na.lan.mwe.com>
Message-ID: <28E139F46D45AF49A31950F88C49745803805FA6@E03MVZ2-UKDY.domain1.systemhost.net>


> But ARIN would put itself at 
> the end of the line of creditors to be paid if it maintains 
> too long a redemption policy before revocation.

ARIN could afford to do that, even if it never gets paid in 
many such situations. As long as the resources are in active
use, then ARIN is fulfilling its purpose.

It also avoids the sticky situation of what to do after revocation.
ARIN can'te exactly prevent the organization from continuing to
use the resources, and if the resources were allocated to another
organization, then they would be embroiled in a technology and
legal tussle to be able to use them.

--Michael Dillon