[arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

[John Curran]

On 27 Feb 2019, at 5:51 PM, Ronald F. Guilmette <rfg at tristatelogic.com> wrote:
> 
> In message <F6B352BB-13A2-43BB-A440-3A3F1019089C at arin.net>, 
> John Curran <jcurran at arin.net> wrote:
> 
>> The registry is public.  The _requests_ to change the registry (which often
>> require detailed technical and business information to meet the policies
>> that this community sets) are not public.
> 
> Thanks for the clarification John.  That's a very very pretty point, and
> one that causes me to wonder if I have misconstrued the allegations that
> have been put forward to justify the proposal.
> 
> Has ARIN merely seen _requests_ to change the registry... requests which,
> in 100% of the cases, ARIN has not actually acted upon... and which appear
> ARIN staff to be suspicious and perhaps even fradulent in some way?

We have seen requests made by multiple parties after the 12 month post-issuance hold down period that have subsequently been withdrawn once ARIN sought further information on why such recently issued resources are now suddenly no longer needed.   In some cases, we have initiated number resource review on such parties, which have resulted in revocation of number resources as a result. 

> I quote directly from the original proposal problem statement:
> 
>     A significant percentage of organizations that receive blocks 
>     from the waiting list subsequently issue these blocks to other 
>     organizations via 8.3 or 8.4 transfers shortly after the one year...
> 
> Maybe I need to take a refresher course on plain English, but it appears
> to me that this says that blocks *were* assigned, and that some such blocks
> *were* subsequently transfered.  So it would appear that we are not talking
> about mere confidential requests here, nor are we talking about any of the
> confidential information that might relate in any way to such requests,
> i.e. while the requests are pending and while they are being evaluated by
> ARIN staff.  Instead, it seems to me, we are talking about both assignments
> and transfers that were in fact made, and that thus should have been duly
> recorded in the public ledger that we call the ARIN WHOIS data base.
> 
> Have I misunderstood?

As noted earlier, a highly disproportionate rate of transfers occurring immediately after the 12 month prohibition of space received via the waiting list policy is quite suggestive of potential number resource fraud, but is not (in and of itself) be determinative of such.  While ARIN has reviewed specific situations and deemed number resource fraud has occurred,  we do not comment publicly on such matters as they are inherently legal situations (e.g. you would not want ARIN making public statements about your purported fraud absent an opportunity to avail your legal rights, and ARIN would be doing a disservice to its community making such statements and creating unnecessary legal risk.)

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers