<div dir="ltr"><div dir="ltr"><br></div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Tue, Jul 26, 2022 at 5:28 PM Ronald F. Guilmette <<a href="mailto:rfg@tristatelogic.com">rfg@tristatelogic.com</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">And as I have said, corporate<br>
entities of this type, together with natural persons, represent the overwhelming<br>
bulk of all ARIN memberships.<br></blockquote><div><br></div><div>Fair enough; we'll limit the discussion to private corporations and natural persons only. </div><div><br></div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex"> Today we're just taking about dead member cleanup, or<br>
the lack thereof. (We can come back and argue about whether or not ARIN<br>
should be collecting beneficial ownership information for non-publicly-<br>
traded companies some other day.)<br>
<br>
All that having been said, it _is_ indeed my opinion that it _is_ ARIN's job to<br>
know at least the identities of all of the legal entities that are its members.<br>
And in general, I believe ARIN _does_ know all of that, except when it comes to<br>
deceased entities, where it appear to be blind as a bat.<br></blockquote><div><br></div><div>If the corporation closes its doors (is deceased, so to speak), files for dissolution, </div><div>and stops paying its bills, the number resources will be reclaimed; John has said </div><div>so repeatedly.</div><div><br></div><div>If the corporation stops doing business, but someone continues to pay the </div><div>bills for it on their behalf, I know from experience that ARIN will continue to </div><div>preserve the number resource registrations associated with the entity.</div><div><br></div><div>If it's a natural person who held the number resources that passes away, </div><div>the estate goes into probate, and if a beneficiary takes over payment of</div><div>the ARIN bills, it's unclear how ARIN would ever know the natural person </div><div>passed away, as there's no requirement that the next-of-kin furnish a </div><div>death certificate to ARIN, or even notify them of the original registrant's</div><div>decease.</div><div><br></div><div> </div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">
>Similarly, when GlobalCrossing was bought by Level3, there was no<br>
>sudden requirement that every record within ARIN that used to say<br>
>"GlobalCrossing" now say "Level3" (I mean Qwest) (no wait, I mean<br>
>CenturyLink) (shoot, no, now I mean Lumen).<br>
<br>
Maybe there should be. Do you have something against Truth in Advertising<br>
when it comes to public-facing WHOIS records?<br>
<br>
(Note: I think that you may possibly be overlooking the possibility that just<br>
because Level3 got acquired by some other legal entity, that DOES NOT<br>
automatically imply that the legal entity known as Level3, Inc. has itself<br>
necessarily ceased to exist. It may still exits and may still be using<br>
the same resources as it has in the past, all while simply having different<br>
ownership.)<br>
<br>
>Nowhere does the NRPM say that ARINs records must change<br>
>when the name or owner of a company changes.<br>
<br>
Right. That's what I said. And thus, because of that obvious hole in the<br>
rules, I asked John how anybody outside of ARIN could reliably and independently<br>
check to see that ARIN is actually doing what John claims it is doing, i.e.<br>
cleaning up the leftovers of dead companies and making sure that those remnant<br>
resources get properly assigned to the new legal heirs of the old (and now dead)<br>
company, if any, or properly recycled otherwise.<br></blockquote><div><br></div><div><br></div><div>It's the same as the GlobalCrossing/Level3 etc. situation.</div><div><br></div><div>We don't know if the old companies still exist as legal entities or not; </div><div>it's up to the registrant to update their information as they deem appropriate.</div><div><br></div><div>As long as someone is still paying the bills, we don't know if it's </div><div>the same old company under new ownership, or if all the records </div><div>were migrated to the new company, and someone just failed to </div><div>update the registry appropriately. </div><div><br></div><div><br></div><div> </div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">
<br>
>(You can verify this for yourself by searching through ARIN whois<br>
>records for "global crossing", "Level 3", etc. to see that there has<br>
>been no requirement that records be immediately updated to show<br>
>that ownership and control has changed.)<br>
<br>
Not only is there apparently no requirement for the WHOIS records to be<br>
properly updated "immediately" but apparently there is no requirement for<br>
the WHOIS records to be corrected/updated *ever*.<br>
<br>
You may think that's just swell. I do not. But in any case, for me this<br>
also is somewhat of a side-issue at the moment. My first order concern is to<br>
find out if ARIN really and truly is committed to cleaning up the remnants<br>
of old, dead and defunct companies and persons that were formerly members<br>
but that are now "pushing up daisies" as it were.<br>
<br>
It is still not 100% clear to me that ARIN is doing that, even in cases<br>
where the now-dead members are (to use John's words) "brought to the<br>
attention of ARIN". ARIN may be doing it, or then again, maybe not. It<br>
appears that, as with so many ARIN things, there may be no way for an "outsider"<br>
to know if they are doing it or not. And even if they are doing it, they<br>
may perhaps be doing it on a geological time scale, which for me at least,<br>
would be rather unsatisfying.<br></blockquote><div><br></div><div>Again, though, how do you know a company is defunct, </div><div>versus dormant, versus under new ownership?</div><div><br></div><div>If I had a california company, but decide I don't want to deal with </div><div>california business taxes, and I close down the california corporation </div><div>and incorporate in delaware instead, am I obligated to return the </div><div>number resources, or can I simply update my registry entries to </div><div>the new business address and continue using them?</div><div><br></div><div>If you go trolling through the list of defunct companies, you'd </div><div>see my california business as being defunct; but that wouldn't </div><div>mean ARIN should reclaim my number resources; after all, </div><div>my delaware corporation is happily paying the bills, and the </div><div>billing address for the POC has been updated appropriately.</div><div><br></div><div>Just because you tell ARIN my california corporation is dead </div><div>doesn't mean ARIN is going to reclaim my resources; they may</div><div>well look at it, recognize that the california corporation is dead, </div><div>but a delaware corporation has taken its place, and is paying </div><div>the bills, and thus no action needs to be taken.</div><div><br></div><div>You on the outside may see it as complete inaction on ARIN's</div><div>part after alerting them about my california company going </div><div>defunct; but that doesn't mean on the inside ARIN hasn't looked</div><div>into it and decided that no action was needed.</div><div><br></div><div>If what you're really asking is for ARIN to report on every </div><div>complaint that is issued, even one for which no action is</div><div>taken...that's going to take a change in policy to effect that, </div><div>and berating ARIN for not doing something that isn't dictated</div><div>that they do in policy is a bit far-fetched.</div><div><br></div><div>Matt</div><div><br></div></div></div>