Hello -

I fully support this proposal text. 

Quote:

"Any entity (individual or organization) requesting ARIN issued IP blocks must 
provide ARIN with proof of an established legal presence in the designated ARIN 
region, and have a majority of their technical infrastructure and customers in 
the designated ARIN region. This requirement applies to both IPv4 and IPv6 
address space."

The internet engineering community purposely designed the RIR system to be 
regional.  Different regions have different needs, and grow at different rates. 
Current NRPM text is deficient in the arena of defining who can, and cannot, 
request number resources from the Registry.  Importantly, staff have (on 
multiple occasions) presented the ARIN community with the challenge of dealing 
with requestors who are trying to "game" the RIR system by obtaining space from 
ARIN when the customers are primarily (and even exclusively) outside the ARIN 
region. The proposed policy text neatly offers staff a good tool to overcome 
those challenges.

The proposed policy text is elegant and operational for a few reasons:

1) If a majority of an organization's customers is outside the ARIN region, 
there organization should be subject to the RIR in which their majority 
resides.  If that majority is in APAC or EMEA, and those regions are out of 
space, that challenge is out-of-scope of ARIN policy. (It is the purview of 
that region's registry and its policy making community.)

2) It does not impede on the ability of global backbone operators to request 
space from ARIN, so long as the ARIN region is the largest consumer of devices 
and addresses. 

3) The use of the term "majority" presents no functional challenges to either 
requestors or staff.  Merriam-Webster has a definition of the word majority 
stating, "the greater quantity or share".

I have only one recommended edit to the text.  I recommend replacing "IP 
blocks" with "number resources", so that the text precisely captures the 
activities of the Registry.

Yours,
David Huberman
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PPML
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