[ppml] Policy Proposal 2005-2: Directory Services Overhaul

Owen DeLong owen at delong.com
Sun Apr 17 17:07:19 EDT 2005

>   Let me give you my own personal opion... Relating to this policy
> discussion...  I feel the only valid reason to 'reclaim' a ARIN resource
> should be FRAUD. Failing to maintain accurate data, should at worst result
> in the removal or flaging of the data, not in reclimation of resources.
> Now, if you could prove that the inaccurate data is actually fraudulent
> data, then reclimation would be reasonable. Now you may think that this is
> somewhat like spliting hairs as to when in-accurate data becomes
> fraudulent data, however I see this a a critical item, and quite frankly
> should be left to the the actual legal system and not ARIN policy or
> staff.
If you provide inaccurate data, and, then, are unreachable, the data is
essentially fraudulent.  If you provide inaccurate data, and, then refuse
to correct it even though you are reachable, the data is definitely
fraudulent, so, yes, I think you are splitting hairs from a practical
ARIN perspective.  ARIN may already reclaim resources for non-payment
of renewal fees.  As such, if ARIN cannot contact you (case 1 above),
you will not receive your bill and it is unlikely the renewal will be
paid.  In the second case, the data qualifies as fraudulent.  If you
pay your fees, but, do not provide current accurate contact data
when you do so, I believe that qualifies as intent to defraud.

>   Let me get back to a specific part of this policy proposal that I don't
> like...
>  "Third parties may report the inability to make contact with a party via
> information in the APID. In this case ARIN shall attempt the contact
> verification procedure for that contact immediately. If a response is
> received, ARIN should document that a problem occurred, and the response
> from the resource holder. Offenders who fail to respond to third parties
> more than 4 times per month for three months may have their resources
> reclaimed at the discretion of ARIN staff." I belive that there are
>    I suggest to you that there can be valid re-assignments of ARIN
> resources, that may for a varitey of reasons become non-responsive for
> preiods of a month or longer, and should not constitute anything close to
> being grounds for reclaimation or maybe not even be grounds for
> 'suspension'(depending on how that is defined).  Consider something such
> as a seasonal business, or a very small busines where possibly the entire
> staff is gone for a month or more. (possibly a small family based
> business, etc...) Well, you say ARIN staff can use there 'discretion' to
> determin that this is something that doesn't constitute a offense.  I say
> that there shouldn't be room for ARIN staffs descretion... The only reason
> for reclaiming resources based on 'inaccurate' or 'non responsive'
> contacts, is FRAUD, which is legaly defined.
And it doesn't... It requires 4 times per month for three months.  There's
legitimate reason for a valid POC for a network resource to be unreachable
for 3 months solid.  A Seasonal business should have a responsive backup
POC from their upstream or such.  Otherwise, the rest of the world is
expected to live with their resources being abused while they aren't
I think that is bad for the world.


If it wasn't crypto-signed, it probably didn't come from me.
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