Howdy folks I very much hope I’m not a significant part of this problem but we 
do submit 50-100 reassigns a week. If there is any evidence of us causing 
trouble in the data I’d be happy to try to run it down and improve. As noted by 
others we do this primarily to offload abuse but also to assist LEO’s and to be 
upfront with the community how our space is being use. We also try as hard as 
we can to populate those records with valid info and have our sales guys 
collect and input into our system then the provisioning team validates at turn 
up and the system auto generates at activation the record. I worry greatly that 
if an entry we send up goes unvalidated for 10 days that it must be deleted. I 
think you are going to be losing a lot of good data of legit usage simply 
because folks maybe too lazy to click off on an acknowledgment. If implemented 
I could be sending all these updates and not seeing them appear and wondering 
till 10 days down the road which ones I have to reattempt? Will there be a 
notification back that the record did not populate? That reattempt piece will 
be a lot of fun to workout with our IT guys I can tell you it’ll just be 
dropped for a long time until they work out the code to automate and thus 
usability of whois will be impacted.


Anthony Delacruz
Senior Lead Engineer
IP Admin Backbone Planning and Design
Office: +1 703 363 8503
anthony.delac...@centurylink.com
ipad...@centurylink.com



From: ARIN-PPML [mailto:arin-ppml-boun...@arin.net] On Behalf Of John Santos
Sent: Tuesday, April 17, 2018 1:58 PM
To: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
Reassignment


I think anyone who supplies someone else's email address to a third party 
without their permission is responsible for any mail they receive.  Unless a 
SWIPer has permission from their customer to SWIP the customer's email address, 
the ISP doing the SWIPing is responsible, not ARIN.  If they do this repeatedly 
or as a matter of course, they should be barred from SWIPing and any subnets 
they have previously SWIPed should revert to them, making them responsible for 
all network abuse and connectivity problems originating from those subnets.

Isn't the entire point of SWIP to allow ISPs to offload the abuse and other 
points of contact to their customers, who presumably are more capable of 
dealing with the issues?  And shouldn't the customers expect to receive email 
at those POC addresses as part of that?  Either the ISP has explained that to 
their customers, who have agreed to this, in which case no mail sent to them as 
a consequence is SPAM, or  the ISP has not, in which case the POC (and SWIP) 
should be removed or never allowed in the first place.



On 4/17/2018 11:11 AM, Christian Tacit wrote:
Hi Jason,

After discussion with staff, I can report that it would be much easier to send 
a notification to the email that is swipped as the POC but to add in any type 
of ACK or NACK turns it into a very, very heavy lift for the organizations as 
it completely changes the flow. Furthemore, the addition of a requirement for a 
response could end up creating issues (whether real or perceived) that ARIN 
would be sending UCE (Unsolicited Commercial Email) (SPAM) to all of those 
contacts as we do not have a formal relationship with them.

Chris


Christian S. Tacit,
Tacit Law

P.O. Box 24210 RPO Hazeldean
Kanata, Ontario
K2M 2C3 Canada

Tel: +1 613 599 5345
Fax: +1 613 248 5175
E-mail: cta...@tacitlaw.com<mailto:cta...@tacitlaw.com>

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From: Jason Schiller <jschil...@google.com><mailto:jschil...@google.com>
Sent: April 16, 2018 3:05 PM
To: Christian Tacit <cta...@tacitlaw.com><mailto:cta...@tacitlaw.com>
Cc: ARIN-PPML List <arin-ppml@arin.net><mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
Reassignment

Chris,

Thanks.

One of the problems with POC validation is that ARIN tries to validate all 
POCS, and does not have a relationship with some.

There is a proposal to reduce the validation to only the set of POCs that ARIN 
has a direct relationship with.

This is problematic because it is through this annual validation that one finds 
they have become a POC on some resource.
So without out the annual check, those organizations will NOT have the 
awareness and knowledge to resolve that issue between themselves.

The solution is a bi-directional check.

I think the ARIN objection is that it is problematic for the SWIPee to modify 
the record of the SWIPer.
But I see no problem with the SWIPee getting notified, or even ACKing or 
NACKIing the SWIP.

__Jason



On Sat, Apr 14, 2018 at 2:23 PM Christian Tacit 
<cta...@tacitlaw.com<mailto:cta...@tacitlaw.com>> wrote:
Hi Jason,

Although I did look into the issue raised by your March 15 email promptly after 
receiving it. I inadvertently forgot to reply to you. Please accept my apology.

Based on ARIN Staff input, a major impediment to the proposed Section 3.8 is 
that ARIN cannot be involved in the contractual relationship between its 
customer and any of the customer’s customers. The ARIN customer may be 
submitting a simple reassignment, precisely because it wants to maintain 
control over POC records. Examples may include branches located in different 
states of an entity that may want to use address information corresponding to 
its  head office and or other locations in which it has a presence. If there is 
a dispute with an entity that already has an OrgID with ARIN and its upstream 
provider on how to register the entity’s reassignments, those organizations 
will have the awareness and knowledge to resolve that issue between themselves.

Chris

From: Jason Schiller <jschil...@google.com<mailto:jschil...@google.com>>
Sent: March 15, 2018 4:29 PM
To: Christian Tacit <cta...@tacitlaw.com<mailto:cta...@tacitlaw.com>>
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy 2017-12: Require POC Validation Upon 
Reassignment

This problem is not scoped only to with a new POC is created.

This was also supposed to be a check in 3.7 to insure a resource is not
randomly SWIP'd to a pre-existing org.

3.8 was intended to chatch when a resource is SWIP'd to a pre-existing org,
but that org ID is not used, and that org's address is put into a reassign 
simple.

I don't see how this is not implementable..

- If the compnay name is a match for something ARIN already has a relationship 
with,
  then they should have good contact info.

- If the contact info is a known address of a compnay that ARIN already has a
  relationship with, then they should have good contact info for that compnay.

- If all else fails they can send a post card to the mailing address.

At a mimimum, if the post card is undeliverable, or a holder of the the post 
card
contacts ARIN, they should revoke the SWIP.

___Jason






On Mon, Mar 12, 2018 at 5:47 PM, Christian Tacit 
<cta...@tacitlaw.com<mailto:cta...@tacitlaw.com>> wrote:
Dear Community Members,

The shepherds for the Draft Policy 2017-12: Require POC Validation Upon 
Reassignment, are making two changes to its text.

First, the problem statement is being expanded a bit to explain how POCs for 
reassigned blocks can be assigned without the knowledge of the individuals so 
assigned under the present policy.

Second, proposed section 3.8 has been deleted. This is because it is 
unintentionally misleading because a simple reassignment results in a customer 
identifier versus an OrgID.   There is no contact information contained in a 
simple reassignment other than street address that could be used for 
notification, and thus it does not appear that the proposed NRPM 3.8 policy 
text is implementable.  Even if notification were possible, the “OR postal 
address” in this section may also cause significant problems for some companies 
as many companies have the same name associated with many different locations 
and there are several locations that have many companies registered there.

Based on these changes, the revised text reads:


Version Date: March 12, 2018



Problem Statement:

Some large ISPs assign individuals to be POCs for reassigned blocks without 
consultation of the individual they are inserting into Whois. For example, 
during the reassignment/reallocation process, some large ISPs automatically 
create POCs from their customer’s order form. This process is automated for 
many ISPs and therefore the resulting POCs are not validated prior to being 
created in the ARIN Whois database. This creates unknowing POCs that have no 
idea what Whois is or even who ARIN is at the time they receive the annual POC 
validation email. It can also create multiple POCs per email address causing 
that same person to receive a multitude of POC Validation emails each year.

This policy proposal seeks to improve the situation where a POC is unwittingly 
and unintentionally inserted into Whois.

It also seeks to mitigate the significant amount of time that ARIN staff 
reports that they spend fielding phone calls from POCs who have no idea they 
are in Whois.

Finally, it is hopeful that this proposal will improve the overall POC 
validation situation, by forcing ISPs and customers to work together to insert 
proper information into Whois at the time of sub-delegation.



Policy statement:

Insert one new section into NRPM 3:

3.7 New POC Validation Upon Reassignment

When an ISP submits a valid reallocation or detailed reassignment request to 
ARIN which would result in a new POC object being created, ARIN must (before 
otherwise approving the request) contact the new POC by email for validation. 
ARIN's notification will, at a minimum, notify the POC of:

- the information about the organization submitting the record; and
- the resource(s) to which the POC is being attached; and
- the organization(s) to which the POC is being attached.

If the POC validates the request, the request shall be accepted by ARIN and the 
new objects inserted into Whois.  If the POC does not validate the request 
within 10 days, ARIN must reject the request.



Timetable for implementation: Immediate

Comments from the community are welcome!


Christian S. Tacit


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--
_______________________________________________________
Jason 
Schiller|NetOps|jschil...@google.com<mailto:jschil...@google.com>|571-266-0006



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_______________________________________________________
Jason 
Schiller|NetOps|jschil...@google.com<mailto:jschil...@google.com>|571-266-0006





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John Santos

Evans Griffiths & Hart, Inc.

781-861-0670 ext 539

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