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

William Herrin bill at herrin.us
Wed Sep 25 18:15:29 EDT 2013

On Wed, Sep 25, 2013 at 5:46 PM, Owen DeLong <owen at delong.com> wrote:
> On Sep 25, 2013, at 11:33 AM, William Herrin <bill at herrin.us> wrote:
>> 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.
> Foreign interests that own ARIN region infrastructure and do business in
> the ARIN region are either legally operating within the ARIN service region,
> or, they are violating the law by doing so, so I am not sure what it is that
> you find objectionable.
> For example, a German company operating in Virginia that has filed all
> of the necessary paperwork, has the proper permits and licenses, etc.
> would qualify under the above provision.

Hi Owen,

What permits, licenses or other government paperwork would a German
company need to own a few routers in Ashburn, buy telco DSL lines on
behalf of lata 236 customers and provide Internet access 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.
> If they aren't operating in the region, why should they be able to receive
> resources from ARIN instead of having to get them from an RIR that serves
> someplace that they do operate?

Operating legally in a region != has a government registered legal
presence in the region

ARIN is not qualified to assess the former and would have a very
difficult time doing so. Staff and counsel made this point in the
analysis of the proposal.

The latter penalizes legitimate organizations for failing to register
with the government in a manner the government itself has not elected
to compel by law, an action far outside ARIN's mission.

Bill Herrin

William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
Falls Church, VA 22042-3004

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