[arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

Mike Burns mike at nationwideinc.com
Thu May 12 13:00:19 EDT 2011

Hi Tom,

I still don't see the connection between my proposal to drop needs 
requirements for transfers and the participation rate of DNS whois or the UK 
land office.
I may be missing something obvious, though.

My whole goal is to increase accuracy in Whois, and I am not relying on any 
financial or price mechanism for that increase.

I have not argued that pricing will increase registration, I have argued 
that pricing will ensure productive use.

I have no policies related to private registries, if you are discussing the 
idea of private registries, then I have some context, but that discussion 
would not belong with this subject line.

(On the subject of subject lines, I will give a nod to the poster who 
complained about the advocacy buried in the name of the proposed policy. My 
tounge was in my cheek when I named it that, I'm lucky I didn't call it the 
Defense of Whois Proposal!)


----- Original Message ----- 
From: "Tom Vest" <tvest at eyeconomics.com>
To: <arin-ppml at arin.net>
Cc: "Paul Vixie" <vixie at vix.com>
Sent: Thursday, May 12, 2011 12:35 PM
Subject: Re: [arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

> On May 12, 2011, at 11:30 AM, Paul Vixie wrote:
>> mike at nationwideinc.com ("Mike Burns") writes:
>>> As far as the DNS private market goes, I don't see the problem with it.
>> see 
>> <http://www.theregister.co.uk/2011/03/17/child_abuse_cop_slams_icann/>,
>> with raw data at <http://svsf40.icann.org/node/22219>.
>> internet resource holders (whether names or numbers) will *not* show more
>> accountability than is required of them by the rest of us.
> Ahh thanks Paul for the reminder that I forgot to to add supporting 
> references for the claims I made last night...
> Corrections inline below...
> On May 12, 2011, at 4:58 AM, Tom Vest wrote:
>> Hi Mike,
>> Thanks for the very detailed response.
>> Given the level of scrutiny that you've obviously devoted to this 
>> particular transfer transaction, and your repeated emphasis on what could 
>> be interpreted as gaps and inconsistencies in the accumulated public 
>> disclosures about this matter,  I am tempted to assume that you are 
>> either a real stickler for legalistic/rule-based/procedural fairness, or 
>> a determined champion of transparency and public disclosure -- or perhaps 
>> both (?).
>> And yet your policy proposals seem to exhibit very little of those 
>> concerns about procedural fairness and transparency -- but quite a bit of 
>> the same sort of fairy tale qualities that you disparage in the official 
>> account of the Nortel/Microsoft transfer justification. To paraphrase 
>> George Berkeley, if a tree falls in the woods but no one's around to hear 
>> it (and/or to witness whether it harms any other trees on the way down), 
>> do we still believe that it makes a sound? Or would be better to infer 
>> from the silence that trees in the forest have become immune to the laws 
>> of gravity, or perhaps that falling trees now spontaneously sublimate 
>> into gas as soon as they start tilting, thus making both sound and harm 
>> impossible? If we put enough distance between ourselves and the forest so 
>> that no sound can ever be heard, does that grant us the license to be 
>> indifferent as to which of these is (more) true -- or to take any 
>> position that appeals to us, regardless of its (in)consistenc
> y with previous observations?
>> The same questions come up in the real world. For example, what does the 
>> generally low quality of domain-related whois data that is commonly 
>> observed in the competitive market for DNS registrar services say about 
>> the notion that the price mechanism alone is sufficient to sustain whois 
>> meaningful registry/whois participation? [1].
> [1] National Opinion Research Center. (2010). Draft Report for the Study 
> of the Accuracy of WHOIS Registrant Contact Information.
> http://www.icann.org/en/compliance/reports/whois-accuracy-study-17jan10-en.pdf
> (see esp. p. 14, which I interpret as indicating that appx. 77% of domain 
> registrant records exhibit some combination of deficiencies that would 
> both (a) make them more-or-less useless for many operational 
> communication/coordination requirements, and as a consequence (b) likely 
> cause them to be flagged as nonconforming (if not something worse still) 
> if someone tried to use them in a number resource registry.
>> What can be inferred from a situation in which a 100% voluntary (and 
>> until very recently, 100% free) registry dedicated to much pricier assets 
>> still only attracts participation at levels that would be fatal to an IP 
>> number resource registry? HM Land Registry in the UK, for example, just 
>> passed the 70% national participation milestone (though participation in 
>> some rural counties remains below 50% ) after only 150+ years of 
>> membership promotion efforts) [2]. What, if anything, do you think that 
>> we can take away from the experiences of other private registries like 
>> these? Why should we assume that the private decision making calculus of 
>> future transfer market participants will favor registration/disclosure 
>> over nondisclosure at rates that are 2-3x higher than observed 
>> participation levels in other private registries?
> [2] HM Land Registry: http://www.landreg.gov.uk/
> See esp. http://www1.landregistry.gov.uk/upload/documents/regdevmap.pdf 
> for county-level "coverage" (or registry participation levels) c. late 
> 2010.
> Lots of other interesting/challenging stuff here, esp. for anyone who 
> assumes that a highly professional and 100% free registry would surely 
> attract high levels of participation.
> TV
>> For the record, I agree with you that the next few years are certain to 
>> test the current registry/whois system more severely than it has ever 
>> been tested in the past. I also believe that that system will continue to 
>> represent the best and only means at "our" (individual and/or collective) 
>> disposal, both for exercising "macro-prudential" judgment in 
>> private/commercial matters, and for serving as informed co-participants 
>> in "macro-prudential" coordination and oversight activities -- a.k.a. 
>> "industry self-governance." These functions are doubly critical in 
>> industries like the ours (which in this sense would include 
>> banking/finance) that are highly dependent on the consistency (or at 
>> least predictability) of transitive commercial interactions. As long as 
>> the "typical" inter-domain packet exchange must traverse 3~4 or more 
>> separate business entities in order to be completed, there is no reason 
>> to believe that "counterparty scrutiny" (or peer-mediated / "market 
>> discipline") alone
>  will be sufficient to keep this industry afloat -- no matter how we 
> reinforce those bilateral levers with (ironclad contracts | secure 
> protocols | interpersonal relationships | faith in the rationality of 
> markets).
>> The banking industry learned that lesson the hard way not so long ago --  
>> or at least I'd like to think that parts of it did, even if there hasn't 
>> been any obvious change in the pace or direction of financial activity 
>> migration away from the "light" of reciprocal disclosure and limited 
>> transparency, and into the "shadows" where nobody knows nothing. 
>> Regardless, I think that *we* should take advantage of the opportunity to 
>> learn from this episode, even if bankers themselves don't. Considering 
>> that Internet industry members still enjoy the kind of operational 
>> autonomy and freedom of private action that US banks once had -- until 
>> their own self-governance mechanisms stopped working (and the Fed took 
>> over, c. 1907), the stakes on the line during the next few years really 
>> couldn't be higher...
>> TV, speaking form myself alone
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