> On 14 Jul 2022, at 5:35 PM, William Herrin <[email protected]> wrote:
> ...
> I think maybe you missed my point. We don't know how ARIN would treat
> Ronald's information if filed in a formal complaint and can't
> rationally discuss whether that enforcement is consistent with our
> policy-level expectations because ARIN doesn't publish enough details
> about the complaints, their investigations and the results.
Bill –
If the community desires such an approach, it can be readily accomplished –
but there is quite a bit to consider (See below.)
Also, I would recommend that some thought be given to the actual “problem”
being solved here, since there may be other approaches with different tradeoffs
that are superior for some classes of problems (e.g., use of a review panel for
requests of concern, more details disposition of fraud or number resource
review
cases, etc.)
> There ought to be a way to open that black box without unduly harming the
> folks who get investigated. Like making it all public upon the
> investigation's conclusion when all the information is on the table.
> Upon finding the complaint unsubstantiated, ARIN could even offer the
> registrant the opportunity to redact anything they considered a trade
> secret before publication. We'd still end up with a heck of a lot more
> information and quite possibly enough information to inform a policy
> discussion.
A few details to consider for those wish to pursue this particular direction of
“making it all public” –
1. While you suggest “trade secret” redaction, I am fairly confident that the
information
withheld from disclosure will be almost always intersect the information
at the crux of
the dispute about the validity of the request, so a very high level of
clarity will need to
be provided since ARIN will effectively be “left on the hook” to
administer that rather
problematic aspect of this new fraud review publication policy.
2. We would need to be exceptionally clear about the possibility of public
review when
requesting supporting information _and in fairness would only be able to
apply it to
number resource requests made after adoption of this fraud review
disclosure policy_
(as parties provided supporting information in the past under a
significantly different
understanding than contemplated in this discussion.)
3. To the extent that public disclosure of fraud report review details is
indeed desired,
I would suggest augmenting NRPM section 12 with the necessary policy and
guidelines,
as the number resource review policy is of similar function, and would
also need be
reconciled with any new public disclosure practices for number resource
review cases.
4. It also goes without saying, but any change in this regard should be
carefully evaluated
by the community not only from the viewpoint of the fraud report submitter
but also from
the viewpoint of those subject to inquisition, as we do rather frequently
receive reports of
alleged number resource fraud that turn out to be the result of
insufficient understanding
on the part of the submitter.
Thanks!
/John
John Curran
President and CEO
American Registry for Internet Numbers
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