[arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors - Revised

[Martin Hannigan]

Fully agreed. This is seemingly running out of control.  To be clear, I
fully support LEA intent. I suspect they are getting bad advice on policy
creation. Let's start over and help.

Best,

-M<



On Wednesday, September 25, 2013, William Herrin wrote:

> On Wed, Sep 25, 2013 at 10:59 AM, ARIN <info at arin.net <javascript:;>>
> wrote:
> > must
> > provide proof that they (1) are an active business entity legally
> > operating within the ARIN service region
>
> Howdy,
>
> Speaking for myself, this is unacceptable. I am adamantly, totally,
> 100% against this, in concept and execution.
>
> This kind of restriction on international commerce is usually reserved
> for national security issues. Foreign interests own ARIN region
> infrastructure and do business with ARIN region customers all the
> time, without registering themselves with the government. Just as
> ARIN-region businesses do in Europe, Asia and elsewhere. Until there's
> a need for employees in a country, it's not generally necessary and
> often inappropriate to incorporate there.
>
> I think ARIN should continue to follow the same ordinary business
> practice everyone else does when it comes to the legal status of its
> registrants: as long as there's a contactable legal existence
> somewhere (and it's incumbent on the registrant to prove it) they
> should pass muster as an organization capable of requesting resources.
>
>
> >, and (2) are operating a
> > network located within the ARIN service region. In addition to meeting
> > all other applicable policy requirements, a plurality of new resources
>
> "Plurality" is a non-starter for me. You really want to do this, pick a
> percent.
>
> The reasons have all been stated before, both in the previous
> discussion, the staff comments and the legal assessment. In context,
> plurality is a sloppy, hard to pin down concept that makes management
> and analysis needlessly hard.
>
>
> > As reported at the last meeting in Barbados, ARIN staff is having
> > difficulty verifying organizations out-of-region. In many of the cases,
> > particularly in VPS (Virtual Private Service), the only information
> > received on these organizations by ARIN is a customer name and IP
> > address. This information cannot be properly verified by ARIN. Accuracy
> > of registration data is critical to not only law enforcement, but the
> > greater ARIN community as it relates to abuse contact and complaints. In
> > fact, most issues facing law enforcement are also shared by legitimate
> > companies attempting, for instance, to identify an organization that has
> > hijacked their IP address space.
>
> Do I correctly read the expectation that the verification process ARIN
> would apply to its direct registrants is expected to be adopted down
> stream by service providers as they assign addresses to their
> customers? What a godawful mess that would make!
>
> If not, then how exactly does the draft policy address the problem noted
> above?
>
>
>
> I don't say this often, but for all of the reasons above I
> respectfully encourage the AC to abandon this proposal. The issues
> raised by our law enforcement colleagues are legitimate, but this
> approach to solving them is not credible.
>
> Regards,
> Bill Herrin
>
>
> --
> William D. Herrin ................ herrin at dirtside.com <javascript:;>
> bill at herrin.us <javascript:;>
> 3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
> Falls Church, VA 22042-3004
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