I would like to quote just one section of Milton's post.  

>Counsel asserts: 

> "the policy will lead to an increase in fraudulent applications from out of 
> region requestors, and issuance of resources to those who fraudulently 
> file, since ARIN is not as well positioned to successfully discover such fraud
> by out of region requestors."

> This is a legitimate concern. But I see no reason why staff cannot deny 
> resources to entities that cannot produce adequate evidence for their claims. 
> Other tweaks to be policy could be conceived that might address this issue, 
> bearing in mind that two previous attempts to define thresholds were not 
> acceptable to the community. Further, the incentive for most fraudulent 
> applications comes from IPv4 scarcity, which has a very limited time horizon. 

Historically, there have been bad actors who have successfully obtained 
substantial IPv4 space from ARIN without having any customers or significant 
equipment in the region. A common method is to set up a routing infrastructure 
inside the ARIN region, and backhaul the traffic to the customers who all 
reside 
and operate in a region which has no IPv4 space available. 

And in my opinion, it is this type of scenario which Counsel is referring to. 

The counter-argument to this concern is to hold off enacting 2014-1 until ARIN 
exhaustion. And I haven't heard a counter-counter-argument. If 2014-1 were
not enacted until IPv4 was out of play, and the only resources that ARIN 
would be giving out are IPv6 blocks and AS numbers, then I fail to see why the 
fraud concern is valid.  If I'm mistaken, I'd like to know how so.

Regards,
David

David R Huberman
Principal, Global IP Addressing
Microsoft Corporation
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