It makes option 3 slightly more palatable, but I would still prefer option 2 as described below.
Owen On Feb 22, 2014, at 3:28 PM, Scott Leibrand <[email protected]> wrote: > There is another restriction already in 8.3, which reads "The source entity > will be ineligible to receive any further IPv4 address allocations or > assignments from ARIN for a period of 12 months after a transfer approval, or > until the exhaustion of ARIN's IPv4 space, whichever occurs first." In light > of that, do you still see a problem with #3? > > -Scott > > > On Sat, Feb 22, 2014 at 3:06 PM, Owen DeLong <[email protected]> wrote: > Several options are being discussed regarding this proposal: > > 1. Use the existing last sentence as is and ask ARIN staff to be particularly > watchful for seeming abuse and to bring such back to the community through > regular Policy Experience Reports. There was discussion about this option > suggesting that by the time abuse was recognized and reported, and given > limited existing free pool stocks and the extended policy development > cycle....this option is mute. > > 2. Remove the clause 'and its subsidiaries' and or modify it in such a way as > to mitigate the risk of a laundering of addresses through fraudulent > transfers, but potentially limit the utility of organizations who may have > complex organizations structures in use internationally. > > 3. Take an alternative tack and simply restrict the Inter-RIR re-org transfer > of the 'recently issued block' only, allowing other existing blocks to be > transferred without restriction by recent block acquisition. This alternative > seems to have been expressed and supported in the recent Atlanta Public > Policy Consultation. > > It is my opinion that option 3 is perilous in that it allows a large resource > holder to sell off their address space out of region while backfilling from > the ARIN free pool. > > As such, I am much more comfortable with option 2. One set of language that > was suggested which I like is: > > “…subsidiaries having been operational for a minimum of 18 months.” > > While this might not prevent all possible subsidiary-based rinse-repeat abuse > scenarios, it would at least prevent the obvious subsidiary created for this > purpose scenario and certainly provides better protections than proposal > number 3. > > I think option 1 is probably an unfair burden for the ARIN staff and makes > policy vague in a way that would be difficult, if not impossible, to reliably > enforce and may be even harder to defend in the event of litigation. This is > strictly my own opinion as a member of the community and I have not discussed > the matter with legal council or even the other members of the AC. > > Owen > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. >
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