<div dir="ltr">Full disclosure: I am a non-RSA legacy holder, and I appreciate the opportunity to comment here.<br><br>For the moment, I'll constrain these remarks to the suitability of this proposal's language to its stated purpose and avoid conflating that with the pros or cons of legacy RSA conversion itself.<br>
<br>
Referring to the active paragraph of the proposal:<br>
<br>
<blockquote style="border-left: 1px solid rgb(204, 204, 204); margin: 0pt 0pt 0pt 0.8ex; padding-left: 1ex;" class="gmail_quote">
To
ensure the integrity of information in the ARIN WHOIS Database a
resource must be under an RSA (either legacy or traditional) in order
to update the WHOIS record. ARIN will not update historical
information in the ARIN Whois Database until the resource holder can
prove the organization's right to the resource.<br>
</blockquote>
<br>
I find in these two sentences an implicit assumption that resource
holders cannot authenticate themselves sufficiently for whois updating purposes
without being under an RSA. I find this assumption faulty. Since
there are arguably many reliable mechanisms for authenticating a resource holder
(thus satisfying the stated motivation of the proposal), it would either be ignorant or
disingenuous to assert that it can only be done via an RSA. In fact, I
fail to see how an RSA, in and of itself, would even satisfy the stated
motivation at all.<br>
<br>
Secondly, unless I'm unaware of another affected group, I believe
the only resource holders that are not already under an RSA (and
therefore affected by this language) are exclusively the set of non-RSA legacy
holders.<br>
<br>
Therefore, the only possible result of this language that I can
currently fathom would be, in effect, the forcible conversion of non-RSA legacy
holders into RSA participants, under the misguided assertion of increased whois update confidence.
Consequently, I'm afraid that I must conclude this proposal is either fundamentally flawed at best, or a
strong-arm sales tactic at worst.<br>
<br>
I therefore oppose this language and recommend the same to others.<br>
<br>
I invite corrections of any misunderstandings under which I might be speaking.<br>
<br>
Best regards,<br>
E. Westbrook<br><br>
</div>