[arin-ppml] 8.2 Transfers at ARIN

[Owen DeLong]

David,

If I were the allegedly acquired party and ARIN transferred my resources based solely on
the statement of some $LARGE_CONVICTED_FELON_SOFTWARE_HOUSE officer, I’d be
very upset if I hadn’t actually been acquired.

I’m not saying that your company was attempting any wrong-doing in this case, but I will say that a
document from an officer of the company which allegedly acquired the other company
really shouldn’t be sufficient and I think that ARIN’s actions were absolutely correct if you
didn’t have something more independent, like a bill of sale, court documents, or documents
signed by officers of the acquired entity.

Owen
 
On Dec 10, 2013, at 4:04 AM, David Huberman <David.Huberman at microsoft.com> wrote:

> In the context of an 8.2 transfer request discussion, John Curran posted:
> 
>> To elaborate a bit, it's important to remember that in the circumstances where someone
>> is attempting to hijack resources (which looks quite similar to those attempting to
>> update resource records but unable or unwilling to provide supporting documentation),
>> there's another party that could be potentially harmed if ARIN does not take reasonable
>> and proper care in processing the request.
> 
> Without question, and ARIN's many years of anti-fraud efforts and organization-wide
> commitment to fighting these scammers deserve a standing ovation.  Leslie and her team
> have fought the good fight for years, and have prevented and stopped huge amounts of
> fraud. Thank you Leslie and ARIN!!
> 
> But there has to be a better way for the 95%+ of requestors who ARE telling the truth;
> whose asserted transactions (company A merged into company B) really did happen, and
> they just want to update Whois records. To give a real-world example of the kinds of things
> I'm talking about ...
> 
> I work for a public corporation.  I cleaned up some of our records this fall.  (I'm still working
> on it, actually.)  For one M&A transaction, I provided a signed, notarized Secretary Statement
> from a high-ranking Officer of my corporation stating unequivocally that the Corporation owns
> all the assets of the former entity.  That letter was rejected as insufficient.
> 
> I can deal with that rejection, as I'm a full-time IPAM person.  But the same response is given
> to small shops where the requestor is also the sole network engineer, and performing all ops 
> functions, and probably all in-house IT, too.  And those processes are way too much for the 
> little guy, in my experience.  And that's why I'm here.
> 
> I'm not trying to pick on anyone with that example.  I've stated very clearly in this thread that it's
> a combination of POLICY and procedure which I believe is standing in the way of 90+%
> approval and completion rates (where the only requests not approved are the ones where
> the requestor is being lazy and doesn't respond to simple queries, and requests that are
> submitted in bad faith).    But the example is apt, I believe.  The process is much too onerous
> for the 95% of 8.2 requestors who are acting in good faith, in my opinion.
> 
> I'd like to introduce policy language which prompts staff review of transfers which will, in
> many cases, require no submission of legal documentation by the requestor where possible.
> I don't know what the language looks like, but I'm actively thinking it through. It would 
> really help if this dialogue was responded to, and continued, with more than just the 
> regular commenting crew.  If you're a network operator, a broker, or anyone with a vested
> interest in helping ARIN get better, please jump in and let's discuss options for helping our RIR
> reach new heights to help the operator community!
> 
> David R Huberman
> Microsoft Corporation
> Senior IT/OPS Program Manager (GFS)
> 
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