On 25 Jun 2013 [email protected] wrote:

> 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 AR
> IN 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 resource
> s 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 eve
> n 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.

What if there is no region in which the 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. 

This may not be true.  "Largest consumer" does not equal "majority". 
There may well be companies and organizations which do not have a majority
of their customers or infrastructure in *any* one region. 

> 
> 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". 

That's only a partial definition.  My dictionary defines majority as "the
greater part or larger number; more than half of a total."  The "more than
half" part is essential to the definition. 

Change "majority" to "plurality" and I have no other objection.

> 
> 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. 

Good with that.

> 
> Yours,
> David Huberman

-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539

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