So what if the policy/process resulted in 8.2 requests being something like:

- submit request form
- attach letter from attorney currently admitted to a bar[1]  indicating the 
transfer request is bona fide

That's how it's done in business when assuming contracts, right?  An attorney 
sends  a letter to the vendor stating that we are assuming the contract rights 
(in this case the RSA) so work with us on that.

Just an idea - thinking out loud of ways to make 8.2s fast and easy.

[1] That may be a U.S.-centric concept.  How does this work in Canada in 
various Caribbean nations?

David R Huberman
Microsoft Corporation
Senior IT/OPS Program Manager (GFS)

________________________________________
From: Owen DeLong <[email protected]>
Sent: Tuesday, December 10, 2013 6:56 AM
To: David Huberman
Cc: [email protected]
Subject: Re: [arin-ppml] 8.2 Transfers at ARIN

David,

If I were the allegedly acquired party and ARIN transferred my resources based 
solely on
the statement of some $LARGE_CONVICTED_FELON_SOFTWARE_HOUSE officer, I’d be
very upset if I hadn’t actually been acquired.

I’m not saying that your company was attempting any wrong-doing in this case, 
but I will say that a
document from an officer of the company which allegedly acquired the other 
company
really shouldn’t be sufficient and I think that ARIN’s actions were absolutely 
correct if you
didn’t have something more independent, like a bill of sale, court documents, 
or documents
signed by officers of the acquired entity.

Owen

On Dec 10, 2013, at 4:04 AM, David Huberman <[email protected]> 
wrote:

> In the context of an 8.2 transfer request discussion, John Curran posted:
>
>> To elaborate a bit, it's important to remember that in the circumstances 
>> where someone
>> is attempting to hijack resources (which looks quite similar to those 
>> attempting to
>> update resource records but unable or unwilling to provide supporting 
>> documentation),
>> there's another party that could be potentially harmed if ARIN does not take 
>> reasonable
>> and proper care in processing the request.
>
> Without question, and ARIN's many years of anti-fraud efforts and 
> organization-wide
> commitment to fighting these scammers deserve a standing ovation.  Leslie and 
> her team
> have fought the good fight for years, and have prevented and stopped huge 
> amounts of
> fraud. Thank you Leslie and ARIN!!
>
> But there has to be a better way for the 95%+ of requestors who ARE telling 
> the truth;
> whose asserted transactions (company A merged into company B) really did 
> happen, and
> they just want to update Whois records. To give a real-world example of the 
> kinds of things
> I'm talking about ...
>
> I work for a public corporation.  I cleaned up some of our records this fall. 
>  (I'm still working
> on it, actually.)  For one M&A transaction, I provided a signed, notarized 
> Secretary Statement
> from a high-ranking Officer of my corporation stating unequivocally that the 
> Corporation owns
> all the assets of the former entity.  That letter was rejected as 
> insufficient.
>
> I can deal with that rejection, as I'm a full-time IPAM person.  But the same 
> response is given
> to small shops where the requestor is also the sole network engineer, and 
> performing all ops
> functions, and probably all in-house IT, too.  And those processes are way 
> too much for the
> little guy, in my experience.  And that's why I'm here.
>
> I'm not trying to pick on anyone with that example.  I've stated very clearly 
> in this thread that it's
> a combination of POLICY and procedure which I believe is standing in the way 
> of 90+%
> approval and completion rates (where the only requests not approved are the 
> ones where
> the requestor is being lazy and doesn't respond to simple queries, and 
> requests that are
> submitted in bad faith).    But the example is apt, I believe.  The process 
> is much too onerous
> for the 95% of 8.2 requestors who are acting in good faith, in my opinion.
>
> I'd like to introduce policy language which prompts staff review of transfers 
> which will, in
> many cases, require no submission of legal documentation by the requestor 
> where possible.
> I don't know what the language looks like, but I'm actively thinking it 
> through. It would
> really help if this dialogue was responded to, and continued, with more than 
> just the
> regular commenting crew.  If you're a network operator, a broker, or anyone 
> with a vested
> interest in helping ARIN get better, please jump in and let's discuss options 
> for helping our RIR
> reach new heights to help the operator community!
>
> David R Huberman
> Microsoft Corporation
> Senior IT/OPS Program Manager (GFS)
>
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