Kevin,

I agree that statistical data should be used in this case to validate that the problem exists. Not only do non-disclosures prevent ARIN from presenting most evidence of specific cases, but ARIN acknowledges that there may be specific instances where transferring out a block received from the waiting list is not fraudulent at all, but due to unusual but legitimate business circumstances. It would not be fair to publicly point out all actors in potential fraud when a few of them might not be culpable. But the statistical evidence is strong enough to indicate that fraud exists.

In that regard, in addition to the data John Curran provided showing the high percentage of larger blocks that have been re-transferred, it's worth reviewing the presentation by John Sweeting at the ARIN 42 meeting last October where he discussed the evidence and solicited possible solutions from the community.

Transcript;
<https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5>https://www.arin.net/vault/participate/meetings/reports/ARIN_42/ppm1_transcript.html#anchor_5

Youtube;
<https://www.youtube.com/watch?v=MJHgs4wWO58>https://www.youtube.com/watch?v=MJHgs4wWO58

Presentation;
<https://www.arin.net/vault/participate/meetings/reports/ARIN_42/PDF/PPM/sweeting-policy.pdf>https://www.arin.net/vault/participate/meetings/reports/ARIN_42/PDF/PPM/sweeting-policy.pdf

Specifically, John discusses the re-transfer statistics, the fact that several waiting list orgs already have at least a /16 of space, and the cases of 8.2 mergers performed by orgs on the waiting list to consolidate their holdings, avoid the one year wait, and then perform an 8.3 transfer.

Regards,

Tom

At 03:06 AM 2/27/2019, Kevin Blumberg wrote:
Ronald,

To be clear. For the purposes of the Policy Proposal I'm perfectly content with the aggregate data that has been provided.

The problem statement from the author, in my view, matches up with the data provided by John Curran.

Kevin

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