Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
Bill - Agreed that the language is oriented to those with existing ARIN context (although this may be somewhat inevitable given that we’re clarifying the deprecation of ARIN-specific jargon…) Do you have any suggestions for improving the policy text? Thanks, /John John Curran President and CEO American Registry for Internet Numbers > On Mar 1, 2024, at 6:17 PM, William Herrin wrote: > > On Fri, Mar 1, 2024 at 1:11 PM ARIN wrote: >> TO: >> >> “Allocation - IP addresses issued directly by ARIN to an organization for >> the purpose of subsequent distribution by the recipient organization to >> other parties or the exclusive use of the recipient organization. >> >> Assignment - IP addresses delegated to an organization directly by ARIN for >> the exclusive use of the recipient organization. [Note: The use of >> assignment as a differentiating term has been deprecated. Assignment should >> instead be read as Allocation.]” > > Hi, > > This only makes sense to someone well versed in the history of ARIN > jargon. It's supposed to be written to make sense to someone who > isn't. > > Regards, > Bill Herrin > > > -- > William Herrin > b...@herrin.us > https://bill.herrin.us/ > ___ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Revised - Draft Policy ARIN-2024-1: Definition of Organization ID/Org ID
Owen - With the preface that ARIN staff do not make policy proposals – but do provide feedback on policy discussions as appropriate – I concur that the more functionally-oriented definition of Org ID does appear to be a step in the right direction, but your point regarding intention to participate in the registry versus holding resources is definitely valid (and thus the wording is likely not a precise as it might be…) I would note that there is an existing definition of Internet number resources in NRPM that references the Internet Numbers Registry System, and one possible approach to defining Org ID could simply observe that those who wish to participate in that system via ARIN services are issued OrdID’s for that purpose; i.e., something to the effect of – An Organization Identifier (Org ID) is an identifier assigned to entities that wish to participate in the Internet Numbers Registry System via ARIN registry services. (and while I hope this feedback is helpful to the community in considering possible evolution of the draft policy, I observe there are likely many other ways to address the issue so in no way should it be considered constraining that evolution.) Best wishes, /John John Curran President and CEO American Registry for Internet Numbers On Feb 8, 2024, at 2:52 AM, Owen DeLong via ARIN-PPML wrote: Since one technically needs to create an ORG-ID in order to request resources (if you don’t already have an ORG-ID), ORG-IDs are technically assigned to entities prior to them obtaining resources. As such, while I think this definition is somewhat on the correct track, technically, it is invalid, so I cannot support as written. Owen On Feb 7, 2024, at 13:05, ARIN wrote: The following Draft Policy has been revised: * ARIN-2024-1: Definition of Organization ID/Org ID Revised text is below and can be found at: https://www.arin.net/participate/policy/drafts/2024_1/ You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate the discussion to assess the conformance of this Draft Policy with ARIN's Principles of Internet number resource policy as stated in the Policy Development Process (PDP). Specifically, these principles are: * Enabling Fair and Impartial Number Resource Administration * Technically Sound * Supported by the Community The PDP can be found at: https://www.arin.net/participate/policy/pdp/ Draft Policies and Proposals under discussion can be found at: https://www.arin.net/participate/policy/drafts/ Regards, Eddie Diego Policy Analyst American Registry for Internet Numbers (ARIN) ARIN-2024-1: Definition of Organization ID/Org ID Problem Statement: During work on a related policy proposal, the NRPM Working Group determined that a definition of Organization Identifier (Org ID) should be included in the NRPM to add clarity to the term and unify NRPM references to match the use of the term in other ARIN publications such as ARIN online. Policy Statement: Current: None Proposed: Section 2.18. Organization Identifier (Org ID) An Organization Identifier (Org ID) is an identifier assigned to resource holders in the ARIN registry. Comments: This definition had previously been included in an earlier policy proposal (ARIN-2023-7), but community feedback recommendations on that proposal showed a preference for adding the definition separately from that proposal. As such the definition is now being proposed as a standalone proposal, and the language will be removed from the current ARIN-2023-7 proposal, allowing the two sections of that proposal to be evaluated separately. Timetable for Implementation: Immediate ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
On Dec 14, 2023, at 7:49 PM, Owen DeLong wrote: On Dec 14, 2023, at 14:45, John Curran wrote: …. I am fairly clear what constitutes an ISP and/or a provider of connectivity services, but what services constitute network services? Does that include an IR that provides VPN/tunnel services? Companies that provide network monitoring services? CDN providers? Networks providing DDoS Mitigation services? Firms that provide IP address management services, including monitoring of one’s routing/IRR/RPKI/geolocation/rDNS status and leasing of IP address space? SAAS operations that provide network configuration, monitoring, and IP address management? Or perhaps “all of the above except for those IR’s that _only_ provide IP address management services” to their customers? Once we step away from ISPs providing connectivity services, things because very fluid and rather quickly. Note - the inherent flexibility of the term “IR” may not be problem what it comes to IPv6, but has obviously has some potential for interesting consequences for IPv4 administration. Right, so in terms of staff interpretation, what would be done with a request for IPv6 resources in each of those scenarios if it arrived today? Owen – I believe that they would all be issued IPv6 resources if they requested such. Note in particular the rather thin difference between "Firms that provide IP address management services, including monitoring of one’s routing/IRR/RPKI/geolocation/rDNS status and leasing of IP address space” when compared to “Firms that provide address block management only” –– this is a very fine distinction indeed for ARIN staff to attempt to assert absent clear policy language and intent. Unless the answer to that question is yes, then I think the correct fix is to explicitly add the appropriate limitation to the definition of LIR, which is likely editorial since it wouldn’t change staff interpretation of the policy. If the answer to that question is yes, then we do, indeed, have an (at least to me) unexpected divergence between current IPv4 and IPv6 policy and I think the community needs to make a decision on whether we wish to continue to permit IPv6 to be handed out to “Address Management Services”. Indeterminate - see above regarding companies providing “network services” (feel free provide any insight based on your understanding of policy intent.) The policy intent was definitely to cover all of the above except address management only. (i.e. all infrastructure based forms of network services). (At least that was the author’s intent when I wrote the policy). Understood and thanks for providing that answer – would it be correct to derive from your answer that you consider VPN, virtual hosting, and "SAAS operations that provide network configuration, monitoring, and IP address management” all to be “infrastructure-based forms of network services”? I care not whether this change ends up editorial or not, my focus is on identifying the correct changes to NRPM to get to the desired result (and, for that matter, if there is a discrepancy between the interpretation being applied to IPv6 policy and IPv4 policy, whether or not the community wishes to continue that difference or which direction to go). In general, I personally favor prohibiting “Address Management Services” without connectivity. Policy proposals are relatively easy to submit if you wish to make NRPM clearer in any manner. I’m sure you are well aware that I am quite familiar with the PDP and how to submit a proposal. ;-) Nonetheless, I’d like to see clearer answers to the questions you keep side-stepping and further community comment on which way the community as a whole wants to go on the issue. No intention of side-stepping, but providing answers to hypothetical requests requires a bit of care (and in cases of ambiguity of policy language it also necessitates review of the policy development.) I don’t mind writing a policy proposal, it certainly won’t be my first, but I think it’s reasonable to first try to get a sense of what is likely to achieve support from the community and to get a firm stake in the ground as to where current policy actually stands. The present policy language in NRPM doesn’t require that an LIR’s “network services” be for provision of connectivity, nor that they be “infrastructure based” – the staff implementation is faithful to the policy language, and if your intention was otherwise, then it is worth considering potential policy changes with respect to IPv6 policy language given the definition of the term LIR. ( and to the extent that community moves from the term “ISP” to “LIR” for IPv4 policy language, a similar condition would be created. ) Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Pub
Re: [arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
On Dec 14, 2023, at 4:34 PM, Owen DeLong wrote: Does this mean that ARIN will issue IPv6 to LIR requests with a stated intent to go into the IP resource management business separate from providing connectivity services? Owen - That may come down to any distinction between “connectivity” versus “network” services… to the extent there is ambiguity in number resource policy, ARIN tries to work with the requesters to get their request for resources _approved_ to the extent that it can be done within the expressed language and intent of the number resource policy as written. Per NRPM section 2.4, a "Local Internet Registry (LIR)" is an IR that primarily assigns IP addresses to the users of the “network services" that it provides. It’s also noted that "LIRs are generally Internet Service Providers (ISPs)", but that clearly leaves open that possibility that some LIRs are not ISPs. I am fairly clear what constitutes an ISP and/or a provider of connectivity services, but what services constitute network services? Does that include an IR that provides VPN/tunnel services? Companies that provide network monitoring services? CDN providers? Networks providing DDoS Mitigation services? Firms that provide IP address management services, including monitoring of one’s routing/IRR/RPKI/geolocation/rDNS status and leasing of IP address space? SAAS operations that provide network configuration, monitoring, and IP address management? Or perhaps “all of the above except for those IR’s that _only_ provide IP address management services” to their customers? Once we step away from ISPs providing connectivity services, things because very fluid and rather quickly. Note - the inherent flexibility of the term “IR” may not be problem what it comes to IPv6, but has obviously has some potential for interesting consequences for IPv4 administration. Unless the answer to that question is yes, then I think the correct fix is to explicitly add the appropriate limitation to the definition of LIR, which is likely editorial since it wouldn’t change staff interpretation of the policy. If the answer to that question is yes, then we do, indeed, have an (at least to me) unexpected divergence between current IPv4 and IPv6 policy and I think the community needs to make a decision on whether we wish to continue to permit IPv6 to be handed out to “Address Management Services”. Indeterminate - see above regarding companies providing “network services” (feel free provide any insight based on your understanding of policy intent.) I care not whether this change ends up editorial or not, my focus is on identifying the correct changes to NRPM to get to the desired result (and, for that matter, if there is a discrepancy between the interpretation being applied to IPv6 policy and IPv4 policy, whether or not the community wishes to continue that difference or which direction to go). In general, I personally favor prohibiting “Address Management Services” without connectivity. Policy proposals are relatively easy to submit if you wish to make NRPM clearer in any manner. Thanks (and Happy Holidays!) /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
> On Dec 13, 2023, at 6:57 PM, o...@delong.com wrote: > > At the time, the concept of address registration without network services by > other than RIR had not occurred to me Owen - Whether it occurred to you or not is immaterial. The fact that there is an actual difference in scope between the scope of the two terms is rather important. ARIN does not maintain your presumed scope of the Section 6 LIR equivalence language when considering applications under NRPM Section 4.1.8 / 4.2 (“Allocations to ISPs”) — rather ARIN continues to use the community’s present “ISP” definition contained in the NRPM definitions section. Changing this ISP definition can indeed impact policy implementation beyond what an errata can (or should) address. So, while that should not inhibit policy (or language) changes if sought by the community, it does highlight the need for the community be quite explicit in its desired policy outcomes. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] [MORE] Re: Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
On Dec 13, 2023, at 5:52 PM, John Curran wrote: On Dec 13, 2023, at 5:09 PM, Owen DeLong wrote: My point was that ARIN doesn’t apply those greater constraints and said assumption is actually problematic in that it may dissuade or confuse legitimate applicants. Incorrect - As I indicated earlier, ARIN does consider the term “ISP” and provision of network services in its traditional context; ie, it “ remains applicable to issuance of IPv4 address space under NRPM 4.2 (Allocations to ISPs) as limited by 4.1.8 (ARIN Waitlist). “ If the community wishes it to be otherwise (e.g. taking your IPv6 term definition language into consideration), that change should be made explicitly, and not as an incidental consequence of language cleanup. To be quite explicit (with the goal of more expeditious improving overall understanding) – let me reference back to my previous point regarding "would an organization that _only_ provides address management services for its users be considered an ISP?” There’s little doubt that they would be considered an “LIR”, but if they are not doing the registry services for the provision of any network services, then they are not considered an ISP and do not qualify for IPv4 address space under NRPM section 4.2 & 4.1.8 ARIN Waitlist policy. If the goal is to change this to allow an LIR absent any form of network service provision to obtain IP number resources solely for provision of local registry services, then it would be best if such is done via a policy proposal with a very clear intent section. Absent such a change, ARIN will continue to provide maximum flexibility to organizations that need IP addresses for purposes of provision of network services in wide variety of forms, but that it not the same thing as any “LIR” given that the LIR definition can encompass entities that might obtain addresses solely to provide address management services. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
On Dec 13, 2023, at 5:09 PM, Owen DeLong wrote: A Local Internet Registry (LIR) is an IR that primarily assigns IP addresses to the users _of the network services_ that it provides. LIRs are generally Internet Service Providers (ISPs) whose customers are primarily end users and possibly other ISPs. As such, the question of interchangeability of the ”LIR” and “ISP” terms requires considering whether there is alignment in "the network services” that each provides. I refer you to 6.5.1.a I referred to the NRPM general definitions, rather than language of a specific policy section, ie Section 6 which defines IPv6 Policies for Allocations and Assignments”The general applicability outside of that context is uncertain. It is not appropriate to conclude that NRPM equates the terms, but rather that it only notes that "LIRS are generally ISPs.” –– i.e. the definition clearly envisions the possibility that some LIRs may not be ISPs; they may provide IP addresses to users, but that does not necessarily and automatically equate with "the provision of network services” such as the term Internet Service Providers encompasses. I don’t conclude that, I read it in the text of the NRPM quoted above. Certainly applicable policy language if you’re making an IPv6 request, otherwise indeterminate. See above - alas, the NRPM does not presently call out the terms as equivalent but rather only notes that LIRs "are generally ISPs." It doesn’t in section 2 where it defines LIR, but it does in 6.5.1.a as shown above. Indeed - alas NRPM has to apply to more than IPv6, so at a minimum that definition should move to the general definitions, if the community intends such to be more widely applicable. My point was that ARIN doesn’t apply those greater constraints and said assumption is actually problematic in that it may dissuade or confuse legitimate applicants. Incorrect - As I indicated earlier, ARIN does consider the term “ISP” and provision of network services in its traditional context; ie, it “ remains applicable to issuance of IPv4 address space under NRPM 4.2 (Allocations to ISPs) as limited by 4.1.8 (ARIN Waitlist). “ If the community wishes it to be otherwise (e.g. taking your IPv6 term definition language into consideration), that change should be made explicitly, and not as an incidental consequence of language cleanup. Thanks! (And Happy Holidays!) /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
On Dec 13, 2023, at 1:40 PM, Owen DeLong wrote: On Dec 13, 2023, at 09:09, John Curran wrote: ... I note that that you make a strong presumption about "what ARIN is actually concerned about”, and while registration aspects may frequently be the main focus, it is not necessarily always the case that ARIN’s concerns are limited to "the local registration of addresses to other entities” – ARIN’s remit is set by the member-elected Board per the policies developed by this community, so “what ARIN is actually concerned about” may extend a bit beyond your asserted viewpoint – again, depending on the policies established by the this community. I believe I said “primarily concerned about”. Please don’t disregard important words. Owen - If that’s the case, then my apologies, but our mail server seems to have your email recorded as such – > "Best to avoid the quagmire of ambiguity and talk in terms of what ARIN is > actually concerned about, which is the local registration of addresses to > other entities (whether internal, external, or both). “ So you’re saying that using the term LIR there would bring in unintended recipients? Given that we have already stated in the NRPM that the terms are interchangeable and have the same meaning for policies, this statement is confusing to me. The portion of the NRPM that defines LIR is as follows – A Local Internet Registry (LIR) is an IR that primarily assigns IP addresses to the users _of the network services_ that it provides. LIRs are generally Internet Service Providers (ISPs) whose customers are primarily end users and possibly other ISPs. As such, the question of interchangeability of the ”LIR” and “ISP” terms requires considering whether there is alignment in "the network services” that each provides. Certainly in many cases an LIR is an ISP (and the NRPM LIR definition makes that plain in its second clause), but to draw an example: would an organization that only provides address management services for its users be considered an ISP? It is not appropriate to conclude that NRPM equates the terms, but rather that it only notes that "LIRS are generally ISPs.” –– i.e. the definition clearly envisions the possibility that some LIRs may not be ISPs; they may provide IP addresses to users, but that does not necessarily and automatically equate with "the provision of network services” such as the term Internet Service Providers encompasses. That does not mean that “LIR” is not a suitable replacement for ISP in the NRPM, but rather that the community will need to be clear if there are any additional assumptions or constraints applicable to portions of the policy that may have traditionally been assumed due to usage of the term “ISP”. Extracting and making explicit such conditions makes for clearer policy, and as such, moving to “LIR” as the more general term may actually facilitate clearer ARIN number resource policy over the long term – so long as appropriate care is taken in the update. I’m all for due diligence in the process, it given that the NRPM already calls out the terms as equivalent for policy purposes, the idea that it would change the meaning of the current policy is confusing to me. See above - alas, the NRPM does not presently call out the terms as equivalent but rather only notes that LIRs "are generally ISPs." ... As noted, such a change may be more _or less_ descriptive to actual policy intent of particular sections of NRPM , but the community certainly has the ability to consider such cases and clarify as needed. I believe that as implemented currently, the section you cite is used to issue addresses to a number of entity types that many would assume are not “ISPs”. Thank you – you nicely make my point that there may be usage of the term ISP that people believe is more constrained that the term LIR – again, this doesn’t argue against moving to using LIR as the consistent term throughout NRPM, but simply notes that care should be taken to make sure the resulting NRPM policy is unambiguous within the community regarding its policy intent – particular when it comes to policy that is presently references and it utilized by ISPs. Thanks (and Happy Holidays!) /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Sections 6.5.1.a and 6.5.1.b - More section 6 Potential simplifications from the NRPM Working Group
> On Dec 12, 2023, at 2:18 PM, owen--- via ARIN-PPML wrote: > > ISP is a very ambiguous term which carries a lot of different connotations to > different people, most of which don’t describe the full range of ARIN member > LIRs. > > LIRs include cloud providers, CDNs, certain government entities, colocation > facilities, “eyeball” providers, backbone providers, tunnel/vpn service > providers, SDWAN providers, SAAS providers, etc. Owen - It is indeed the case that “ISP” incorporates connections that traditionally have included the provision of Internet connectivity services to “customers” (often commercial, but not always.) > Sure, most of those could be called an ISP under some definition of the term, > but would be excluded from the term in many other people’s minds. Indeed. > Best to avoid the quagmire of ambiguity and talk in terms of what ARIN is > actually concerned about, which is the local registration of addresses to > other entities (whether internal, external, or both). I note that that you make a strong presumption about "what ARIN is actually concerned about”, and while registration aspects may frequently be the main focus, it is not necessarily always the case that ARIN’s concerns are limited to "the local registration of addresses to other entities” – ARIN’s remit is set by the member-elected Board per the policies developed by this community, so “what ARIN is actually concerned about” may extend a bit beyond your asserted viewpoint – again, depending on the policies established by the this community. There are certainly cases where the term ISP is used in its traditional context – for example, NRPM "4.2.1. Principles / 4.2.1.1. Purpose” reads "ARIN allocates blocks of IP addresses to ISPs for the purpose of reassigning and reallocating that space to their customers”, and this section remains applicable to issuance of IPv4 address space under NRPM 4.2 (Allocations to ISPs) as limited by 4.1.8 (ARIN Waitlist). To the extent that a more general term LIR gets used rather than “ISP”, it would represent a change to policy intent unless additional verbiage was added noting the intention of NRPM 4.2 to apply to particular type of LIR… That does not mean that “LIR” is not a suitable replacement for ISP in the NRPM, but rather that the community will need to be clear if there are any additional assumptions or constraints applicable to portions of the policy that may have traditionally been assumed due to usage of the term “ISP”. Extracting and making explicit such conditions makes for clearer policy, and as such, moving to “LIR” as the more general term may actually facilitate clearer ARIN number resource policy over the long term – so long as appropriate care is taken in the update. > As such, yes, I have a strong belief that LIR is a term better suited to ARIN > policy as it is both more descriptive of the bodies being described and more > relatable to the policy intent. As noted, such a change may be more _or less_ descriptive to actual policy intent of particular sections of NRPM , but the community certainly has the ability to consider such cases and clarify as needed. Thanks (and Happy Holidays!) /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Making the Sausage (was: re: AC Candidate [...etc...] )
On Oct 30, 2023, at 6:52 PM, William Herrin wrote: ... If nominated, I'll run. If elected I'll serve. I won't nominate myself. Bill – Technically, you’ll need to nominate yourself at some point, as ARIN eliminated third-party nomination of candidates in order to reduce complexity of the election process (i.e. eliminating some of the edge cases that caught folks in the past regarding handling of last minute nominations versus candidate application deadlines…) Mind you, that’s doesn’t preclude people from privately (or publicly) suggesting that you run – such can be considered nearly the equivalent to “being nominated” if you choose to treat it in that manner. FYI, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] AC Candidates
On Oct 27, 2023, at 2:32 PM, Owen DeLong via ARIN-PPML wrote: That sounds good in principle, Michael, but the reality is that none of the fora you suggested provide for an interactive discussion amongst the broader community. While it’s true that the general-members list reached the electorate, the impact of the AC is felt not only by the electorate, but also by the broader community. The impact of ARIN’s elections, registration services agreement, Board of Trustee elections, etc. are also all topics that could affect the broader community – so that property (in and of itself) is not a particularly compelling argument for mandate of the use of ppml. There are tradeoffs in having such discussions here on ppml (e.g., not everyone here may necessarily want to be buried in discussion of ARIN election processes) versus the general-member mailing list (where discussion of such minutiae might cause drop in general members interest or participation), so this needs to be carefully considered by the community. We will hold an appropriate consultation in the future to discuss this issue and so that the merits of various approaches can be considered. In the interim, suggestions for the improvements to the ARIN election process should be directed to the ARIN ACSP <https://www.arin.net/participate/community/acsp/> Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Should we disallow an AC member from submitting a policy proposal?
> On Oct 27, 2023, at 2:01 PM, William Herrin wrote: > > On Thu, Oct 26, 2023 at 9:28 AM Andrew Dul wrote: >> Should we disallow an AC member from submitting a policy proposal? > > Hi Andrew, > > You got me thinking about this. There might be a useful change to the > process here. Not disallowed, but: before an AC member can introduce a > policy proposal, require them to post the problem statement (without a > policy proposal) to the PPML and solicit feedback for, say, two weeks. > Make that the only hard restriction on an AC member proposing policy > that is not faced by the general public. > > What do you think? As an relevant side-note, I will observe that there was discussion during the PDP update of requiring that _all_ policy proposals initially start solely as a problem statement, and only after that problem statement had been discussed by the community would work on actual policy proposal text commence. That approach was deemed too restrictive, as sometime as a change to policy text is so straightforward that there was no reason to deprive the community of clear policy change text upfront. I do not know know if the same is the case for your proposed hobbling of the ARIN AC members, but provide it as related background. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] Regarding ARIN's PDP (was: Re: AC Candidates)
> On Oct 27, 2023, at 4:10 PM, John Curran wrote: > >> Does the current process actually achieve that lofty goal? > > Yes. By the way, if you actually wish proof of that, feel free to review the record of the policies recommended to the Board of Trustees for adoption… All of them have first come before an ARIN meeting and received overwhelming community support… While the ARIN AC may run the policy development process, the outputs have all gone before the community and nothing is adopted without clear evidence of strong community support. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] AC Candidates (Chris Tacit)
> On Oct 27, 2023, at 3:17 PM, William Herrin wrote: > > Does holding the substantive discussion in closed meetings while the > bulk of proposals see little or no public comment on the list equate > to the AC *not* dominating the conversation? Bill - The ARIN AC holds quite a bit of discussions about the draft policies, but that discussion focuses primarily on the discussion of the proposals that occurs on this ppml mailing list and on comments raised during the public policy consultation portion of the ARIN meetings. In other words, they discuss your remarks (and the remarks of others) made here. While it is true that the individual ARIN AC members have their own views on draft policies, I have personally seen many occasions where shepards have recommend actions to the contrary due to community support that ran in a different direction. > Does the current process actually achieve that lofty goal? Yes. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] AC candidates
> On Oct 26, 2023, at 12:20 PM, William Herrin wrote: > ... > It plummeted after the Board changed the AC's role from shepherding > policy proposals to developing policy proposals. There is no material change in the role of the ARIN AC in this regard – although I do agree that the role of the ARIN AC in shepherding policies has been made clearer with subsequent updates to the ARIN Policy Development Process (PDP). > IMO, one of the worst decisions the board has made. Why should any > member of the general public make the effort to craft a proposal when > it's going to be committeed to death before it can come to a consensus > call? It is true that the ARIN AC is responsible for shepherding all draft policies in the policy development process, and this includes holding the “editor’s pen” when it comes to making changes to draft policies. This has always been the case, but updates to the PDP have made this clearer over the years. Any member of the community can submit a policy proposal, and there are petition options at each stage of the process if one wishes to overturn the actions of the member-elected ARIN AC in its handling of policy proposals or draft policies Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
On Oct 3, 2023, at 1:05 AM, John Santos wrote: On 10/2/2023 5:42 PM, John Curran wrote: Alas, your proposed analogy fails when there is no vehicle, but only the registry entry itself – i.e. Internet number resources are unique identifiers within the Internet Numbers Registry System, and this includes ranges (or “blocks”) of contiguous Internet Protocol (“IP”) addresses and Autonomous System Numbers (“ASNs”)… I disagree. The registry entry itself is *NOT* just the address range (block) or ASN. It is a tuple consisting of a resource (the block of IP4 or IP6 addresses or an ASN) *AND* a holder of that resource. On this we actually agree: note that I said “(the analogy fails when there is) only the registry entry itself" not “only an address range" – the registry entry consists of an address range _and_ the holder of the resource _and_ any associated parameters. The function of a registry is to maintain that list of tuples, insure uniqueness (including overlaps and subsets) of the resources (there can only be one holder for a particular block or ASN, although a holder can be associated with multiple resources), and define requirements for holders to register blocks or ASNs. I think it is losing sight of the fact that the registry is a list of tuples, not just a list of integers, that causes a lot of confusion. Alas, there is no confusion in this regard – the confusion exists on how registry entries are actually created, despite this having undeniably been done over time through “allocation” and “assignment” processes. In ARIN, we have historically used the term “allocation" for registry entries issued to ISPs, and “assignment" for registry entries issued to end-users. The terms “Direct Assignment” and “Direct Allocation” reflect the output of actual processes that occurred, and hence the terminology is accurate. Registration is a wholly distinct principle, in which a party presents an item, has it cataloged, and receives a unique identifier or handle for that item – this is indeed what occurs with titles to tangible items such as property and motor vehicles, but also intangible items such as the issuance of patent numbers for inventions. (i.e., in the cases of registration, the item exists independently of its cataloging) ARIN presently uses the terms Direct Allocations and Direct Assignments for the address blocks issued to parties, and the community has the option to simplify terminology and just use "Direct Allocations” if it so wishes. Switching to use just the term “Direct Registration” does not appear feasible, as ARIN continues to make allocations today of both IPv4 and IPv6 number resources and referring to the output of these acts simply as “registrations” of number resources would be inaccurate. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
> On Oct 2, 2023, at 7:30 PM, William Herrin wrote: > ... I'm not, for example, aware of any SWIP obligations I've > picked up due to ARIN restructuring its process. Nor am I aware of > holders of what were formerly allocations being released from their > SWIP obligations. > The policy obligations to record sub-delegations up to the community and set in policy, so yes – to the extent that you make allocations to downstream customers, you are indeed subject to the present policy (NRPM 4.2.3) regarding recording for reallocating address space to customers. You may operate in a manner without such subdelegations (as is the case for most organizations operating as an "end-users”) – in which case such requirements don’t come into play. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
> On Oct 2, 2023, at 5:18 PM, Delong.com wrote: > > Agree to disagree… > > “Direct Registration” makes it clear (IMHO) that all that ARIN provides is a > registration. The idea that an address block exists, let alone exists > separate from the registration of same is the source of a great deal of > misunderstanding and confusion in a great many places. > > A proper definition of “Direct Registration” in NRPM could, IMHO, go a long > way towards resolving some of that confusion. > > “Issuance” in addition to being awkward as a noun carries the same baggage > and implications that ARIN is somehow doing something other than registering > the association of a particular block to a particular entity. While this has > been a common and convenient thought process, it has also led to the > perpetuation of the misunderstanding that addresses (and/or groups or blocks > of addresses) are things which are created, put into some form of free pool, > and then issued/allocated from that pool, rather than simply an association > (registration) of integers within a particular registry for a particular > purpose among those who choose to cooperate and interoperate with that > registry. > > “Allocation” in addition to having remaining baggage from previous > utilization (not the least of which is the implication that someone holding > an “allocation” is expected to be some form of ISP or at least some form of > “service provider” or “LIR” that issues addresses to “customers” in many > people’s minds) is also problematic for the same reasons I just outlined for > “Issuance”. While it is true that current practice at ARIN has made it > POSSIBLE for all “assignments” to now be treated that way, it has not moved > all end users into actually being service providers who choose to exercise > this new found capability. > > Indeed, what ARIN does comes most proximate in the real world to various > “registration” functions performed by government entities… e.g. your “vehicle > registration” amounts to an association between a given VIN and a given > entity via a 3rd key (“License Plate Number”). Registering a property deed is > the registration of an association between a particular piece of real estate > (assessors parcel number) and an entity (“owner”), etc. Alas, your proposed analogy fails when there is no vehicle, but only the registry entry itself – i.e. Internet number resources are unique identifiers within the Internet Numbers Registry System, and this includes ranges (or “blocks”) of contiguous Internet Protocol (“IP”) addresses and Autonomous System Numbers (“ASNs”)… It is the association of specific registry entry itself with one party that provides uniqueness and a set of rights on management of that entry, and there’s zero evidence of anything “to register” independent of that entry in the registry.For this reason, referring to an address block as a “direct registration” is inappropriate - the address block is the registry entry, and parties that hold address blocks have specific rights to the entry as spelled out in the Registration Services Agreement. > As such, the more I think about the problem, the more I think that > “registration” is the best choice among those presented so far. If someone > can come up with a better term that has even less baggage (because I agree, > “registration” is not baggage free), then I will gladly support that. IMHO, > Neither “Allocation” nor “Issuance” fit the bill. Direct Allocation and Direct Assignment are the present terms of art. Both reflect accurately what has occurred over time, and they can be retained if desired by the community. The question is whether maintaining “Direct Assignment” as a distinction for some of entries is meaningful – it presently is not from a policy or operations perspective, so it is a very reasonable question for the community to consider. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Revised - Draft Policy ARIN-2022-12: Direct Assignment Language Update
Owen - We’ve got a range of possible terms, and each is imperfect in one or more aspects – “Direct Registration” actually has different interpretations, including the concept that an address block is distinct from the registration of same. For this reason alone, it’s likely less than ideal. “Direct Issuance" would appropriately cover both assignments and allocations, but is awkward to use as a noun. “Direct Allocation” is both well understood and encompasses how these address blocks are handled at the present time (and more accurate in many cases as a result of the evolution of the industry towards cloud and hosted service providers.) Anyone looking at how these blocks are handled today will not be confused by the term of art since it is being used in its classic meaning – and if indeed changing Direct Assignment to Direct Allocation results in any degree of confusion, then the same confusion (or more) would quite likely result from changing both to new terminology altogether. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Oct 2, 2023, at 12:58 PM, Owen DeLong via ARIN-PPML wrote: John, At least in my case, this was previously well understood. I appreciate your clarification, but I stand by my suggestion that a new term should be applied. I think “direct registration” is probably the best choice of language. Issuance implies that ARIN had possession of a thing and provided that thing to the registrant. In reality, nobody possesses or owns integers, but ARIN registers particular integers to particular organizations with the intent that said registrations remain unique within the given registry (system) for a particular purpose. Owen On Oct 2, 2023, at 09:30, John Sweeting wrote: Hello all, ARIN staff would like to provide the following clarification on this change. The changes being requested in the NRPM through this policy (2022-12) are simply to ensure the NRPM stays synched with the current operational practices of ARIN. Due to the fee harmonization completed in 2022 ARIN no longer does Direct Assignments, ARIN only does Direct Allocations. Direct Allocations have all the same properties that they have always had. The difference in services being that both ISPs and End Users can now make reassignments and reallocations. Hope that helps. John S. On 10/2/23, 12:22 PM, "ARIN-PPML on behalf of Owen DeLong via ARIN-PPML" mailto:arin-ppml-boun...@arin.net> on behalf of arin-ppml@arin.net <mailto:arin-ppml@arin.net>> wrote: On Oct 2, 2023, at 07:21, Pellak, Kaitlyn via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: Hi all, The rationale used was that it was more straightforward to revise the definition across the NRPM rather than replace each relevant instance of “allocation” and “assignment” with another term (allocation appears 245 times, and assignment appears 101 times.) I'm sure this has already been addressed but could we not simply "find and replace" allocation and assignment with the new terms in the NRPM? If not, perhaps we should consider a way to make those and similar updates given the ever-changing nature of internet terminology. Expressing that to the community gets a bit more complicated than the act of doing so. However, I feel that the effort is warranted for the reasons previously stated. Owen Best, Kaitlyn Kaitlyn Pellak Amazon – Technical Business Developer II kaitj...@amazon.com <mailto:kaitj...@amazon.com> <mailto:kaitj...@amazon.com <mailto:kaitj...@amazon.com>> 301.921.5566 On 10/1/23, 7:10 AM, "ARIN-PPML on behalf of William Herrin" mailto:arin-ppml-boun...@arin.net> <mailto:arin-ppml-boun...@arin.net <mailto:arin-ppml-boun...@arin.net>> on behalf of b...@herrin.us <mailto:b...@herrin.us> <mailto:b...@herrin.us <mailto:b...@herrin.us>>> wrote: CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you can confirm the sender and know the content is safe. On Sat, Sep 30, 2023 at 6:39 PM Douglas Camin mailto:d...@dougcamin.com> <mailto:d...@dougcamin.com <mailto:d...@dougcamin.com>>> wrote: Reading the terms Allocation and Assignment, I see the primary distinction between them as one is “for you” and one is “for you to give to others.” Hi Douglas, To the extent that there was a "primary" distinction, it's that one was for organizations acting like an ISP and one was for organizations acting like end-users. The associated nuance was extensive: everything from how you justified addresses to your public reporting responsibilities to not only how much you paid but the very framework for determining how much you paid. That's what made them "terms of art." https://www.justia.com/dictionary/term-of-art/ <https://www.justia.com/dictionary/term-of-art/>
Re: [arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?)
Michel - That might help for transfers that are completed, but does nothing about facilitators that aren’t really qualified and never manage to get a transfer completed – despite representations of their purported capabilities to do so. To the extent that you wish some form of public reporting for transfers, it’s simple enough to achieve if there’s community consensus for such - summit a policy proposal if you wish this considered by the community. Thanks! /John John Curran President and CEO American Registry for Internet Numbers > On Jun 4, 2023, at 3:47 PM, Michel Py > wrote: > > >> >> John Curran wrote : >> [..] one with a lower probability that those selecting a facilitator from >> the list will end up dissatisfied. > > A good start would be to make the process transparent : for each transaction, > have all of the details made public : the block size, the price, and the fees > paid by all parties. > Maybe that would alleviate the feeling of dealing with a used car salesman > for some. An honest market is a transparent market. > > Michel > ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?)
Mike - It’s still a simple service for the community, but now hopefully one with a lower probability that those selecting a facilitator from the list will end up dissatisfied. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Jun 4, 2023, at 1:35 PM, Mike Burns wrote: Hi John, Not an argument, I just think it was a Freudian slip that revealed the underlying purpose of the entire exercise-creating a list of “trusted” brokers. Why even “qualify” brokers? Why does ARIN feel the need to take a step that no other registry has felt the need to take. Every RIR including ARIN specifically takes pains to separate the brokers from the registry in terms of agency and in terms of registry approval. These lists are merely shingles hung out by those who claim to be brokers, and the list is just a starting point for participant due diligence. It’s a simple service to the community. Now it’s become something more and once again, not a lawyer, but it seems like these actions actually open the door for ARIN liability. Why add the “heft” now, after a dozen years? Why add the imprimatur of ARIN to some brokers at this point? I don’t get it. Regards, Mike From: John Curran Sent: Sunday, June 4, 2023 1:08 PM To: m...@iptrading.com Cc: PPML Subject: Re: [arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?) Mike - One can argue about the optimum terminology to use in the program title, but what is most important aspect of ARIN’s liability is that the qualifications are clear and uniformed applied - customers need to be able to know and trust the level of vetting that ARIN does/does not apply to these facilitators. At this time, we don’t see straightforward way to uniformly apply the requirements that without the facilitators being legally registered entities in good standing within ARIN’s region, but not adverse to expanding the program over time if we can see a way to do so without endangering the integrity of the program. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Jun 4, 2023, at 12:36 PM, Mike Burns mailto:m...@iptrading.com>> wrote: One more thing John…. You keep referring to his as the “Trusted” Facilitator program, not Qualified. Why does ARIN feel to the need to create a trusted list, doesn’t that open ARIN to even more liability exposure? Regards, Mike From: ARIN-PPML mailto:arin-ppml-boun...@arin.net>> On Behalf Of John Curran Sent: Sunday, June 4, 2023 12:27 PM To: PPML mailto:arin-ppml@arin.net>> Subject: [arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?) Importance: High Folks - I’d like to briefly address some of issues that have arisen in this thread about the forthcoming ARIN Trusted Facilitator Program and its associated fee change. First, in terms of discussing this topic on ppml, this is probably the best course of action today – despite the long-term desire that discussions of ARIN services and fees eventually migrate to the general-member mailing list. The reason for this is that many in the community who are interested in such topics haven’t (yet) opted to become a general member and thereby joined the associated list, but also because at the present time general member status is only open to those either holding IPv4 or IPv6 number resources under registration services plan, and doesn’t include facilitators without resources, those who simply have an ASN, etc. In terms of the fee increase for participation in the ARIN Trusted Facilitator Program, this is driven entirely due to the anticipated costs of administration – the new program has quite a bit of “heft” to it in order to ensure that the participating facilitators are able and motivated to provide robust assistance to those enlisting their services. Amongst other requirements this includes the employment at least two individuals who have passed a new certification program on Transfers at ARIN. ARIN has not historically administered any certification programs, and this requirement is driving some additional costs that are reflected in the increased fee for the ARIN Trusted Facilitator Program. Note that information about both the trusted facilitator program and addition of a certification program manager were shared with the community during ARIN 51 during the Customer Experience and Strategy Update <https://www.arin.net/participate/meetings/ARIN51/materials/wednesday/ARIN51_cxsupdate.pdf> – the only feedback received at that time was several customers sharing accolades about improved processing times that they had recently experienced with their ARIN tickets. However, we remain open to any/all feedback from the community on this new program and the related fee change, and as many folks are aware, we are not shy about adjusting the fee structures at ARIN to more
Re: [arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?)
Mike - One can argue about the optimum terminology to use in the program title, but what is most important aspect of ARIN’s liability is that the qualifications are clear and uniformed applied - customers need to be able to know and trust the level of vetting that ARIN does/does not apply to these facilitators. At this time, we don’t see straightforward way to uniformly apply the requirements that without the facilitators being legally registered entities in good standing within ARIN’s region, but not adverse to expanding the program over time if we can see a way to do so without endangering the integrity of the program. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On Jun 4, 2023, at 12:36 PM, Mike Burns wrote: One more thing John…. You keep referring to his as the “Trusted” Facilitator program, not Qualified. Why does ARIN feel to the need to create a trusted list, doesn’t that open ARIN to even more liability exposure? Regards, Mike From: ARIN-PPML On Behalf Of John Curran Sent: Sunday, June 4, 2023 12:27 PM To: PPML Subject: [arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?) Importance: High Folks - I’d like to briefly address some of issues that have arisen in this thread about the forthcoming ARIN Trusted Facilitator Program and its associated fee change. First, in terms of discussing this topic on ppml, this is probably the best course of action today – despite the long-term desire that discussions of ARIN services and fees eventually migrate to the general-member mailing list. The reason for this is that many in the community who are interested in such topics haven’t (yet) opted to become a general member and thereby joined the associated list, but also because at the present time general member status is only open to those either holding IPv4 or IPv6 number resources under registration services plan, and doesn’t include facilitators without resources, those who simply have an ASN, etc. In terms of the fee increase for participation in the ARIN Trusted Facilitator Program, this is driven entirely due to the anticipated costs of administration – the new program has quite a bit of “heft” to it in order to ensure that the participating facilitators are able and motivated to provide robust assistance to those enlisting their services. Amongst other requirements this includes the employment at least two individuals who have passed a new certification program on Transfers at ARIN. ARIN has not historically administered any certification programs, and this requirement is driving some additional costs that are reflected in the increased fee for the ARIN Trusted Facilitator Program. Note that information about both the trusted facilitator program and addition of a certification program manager were shared with the community during ARIN 51 during the Customer Experience and Strategy Update <https://www.arin.net/participate/meetings/ARIN51/materials/wednesday/ARIN51_cxsupdate.pdf> – the only feedback received at that time was several customers sharing accolades about improved processing times that they had recently experienced with their ARIN tickets. However, we remain open to any/all feedback from the community on this new program and the related fee change, and as many folks are aware, we are not shy about adjusting the fee structures at ARIN to more equitably recover costs associated with registry services. It is to be expected that once the Trusted Facility and associated certification program have been operational for some time, we will review the level of participation received, the associated costs, and determine if any adjustments are warranted to provide for more equitable cost recovery. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] ARIN Trusted Facilitator Program and Certification Requirements (Re: Tenfold fee increases?)
Folks - I’d like to briefly address some of issues that have arisen in this thread about the forthcoming ARIN Trusted Facilitator Program and its associated fee change. First, in terms of discussing this topic on ppml, this is probably the best course of action today – despite the long-term desire that discussions of ARIN services and fees eventually migrate to the general-member mailing list. The reason for this is that many in the community who are interested in such topics haven’t (yet) opted to become a general member and thereby joined the associated list, but also because at the present time general member status is only open to those either holding IPv4 or IPv6 number resources under registration services plan, and doesn’t include facilitators without resources, those who simply have an ASN, etc. In terms of the fee increase for participation in the ARIN Trusted Facilitator Program, this is driven entirely due to the anticipated costs of administration – the new program has quite a bit of “heft” to it in order to ensure that the participating facilitators are able and motivated to provide robust assistance to those enlisting their services. Amongst other requirements this includes the employment at least two individuals who have passed a new certification program on Transfers at ARIN. ARIN has not historically administered any certification programs, and this requirement is driving some additional costs that are reflected in the increased fee for the ARIN Trusted Facilitator Program. Note that information about both the trusted facilitator program and addition of a certification program manager were shared with the community during ARIN 51 during the Customer Experience and Strategy Update <https://www.arin.net/participate/meetings/ARIN51/materials/wednesday/ARIN51_cxsupdate.pdf> – the only feedback received at that time was several customers sharing accolades about improved processing times that they had recently experienced with their ARIN tickets. However, we remain open to any/all feedback from the community on this new program and the related fee change, and as many folks are aware, we are not shy about adjusting the fee structures at ARIN to more equitably recover costs associated with registry services. It is to be expected that once the Trusted Facility and associated certification program have been operational for some time, we will review the level of participation received, the associated costs, and determine if any adjustments are warranted to provide for more equitable cost recovery. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Recommended Draft Policy ARIN-2022-11: Clean-up of NRPM – Introduction of Section 2.17
On Mar 22, 2023, at 11:27 AM, William Herrin wrote: Asked and answered. Perhaps you missed it the first two times around? ... https://lists.arin.net/pipermail/arin-ppml/2023-January/070202.html You propose - Computer network protocols often use unique integers to identify computers and functions within the network. Examples include IP addresses in versions four and six of the Internet Protocol and Autonomous System Numbers in the Border Gateway Protocol. The Regional Internet Registries, including ARIN, manage the registration of such Number Resources by the organizations which use these network protocols, assuring that two organizations do not end up with the same numbers. and then elsewhere suggest "The point of section 2 is to render technical jargon in terms of -ordinary English-." Alas, Number Resource Policy Manual is not intended as a primer on computer networking, and the point of section 2 is rather to provide technical definitions for a technical audience. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Recommended Draft Policy ARIN-2022-11: Clean-up of NRPM – Introduction of Section 2.17
On Mar 21, 2023, at 8:33 PM, William Herrin wrote: ... Worse still: RFC 7020 never explicitly defines Internet Numbers or Internet Number Resources, the thing section 2.17 is trying to explain. It defines the "Internet Numbers Registry System.” Bill - You are correct that the term “Internet Number Resources” are not explicitly defined in RFC7020 – nor is it presently defined in the ARIN Number Resource Policy Manual (NRPM). Draft policy ARIN-2022-11 strives to remedy this situation with respect to the ARIN NRPM by introducing the following definition - “Internet number resources are unique identifiers within the Internet Numbers Registry System [as described in IETF RFC 7020] and this includes ranges (or “blocks”) of contiguous Internet Protocol (“IP”) addresses and Autonomous System Numbers (“ASNs”).” A reader can infer through context that Internet Number Resources are IP addresses and AS numbers, just as they can with the NRPM, but RFC 7020 never actually says so. The very first sentence of RFC 7020 reads as follows - This document provides information about the current Internet Numbers Registry System used in the distribution of globally unique Internet Protocol (IP) address space and autonomous system (AS) numbers. making the context obvious and the level of inference necessary rather trivial. However, if you believe that the proposed definition can be improved, you should suggest specific wording changes to achieve such (as comments simply suggesting "a competent rewrite” provide no meaningful information for the ARIN AC to use towards improvement of the draft policy.) Alternatively, if you believe that the policy should not be worked on at all (and instead abandoned), it would be helpful to understand your reasoning for such a perspective. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Are we an ISP or an End-User? Can our designation change at a later time?
> On Jan 5, 2023, at 4:29 AM, Glen A. Pearce wrote: > > On 04/01/2023 1:52 p.m., Fernando Frediani wrote: >> >> Interesting this topic. Generally speaking I always found a bit strange (not >> only in ARIN) to have this distinction between ISP and End-user. In practice >> things should not differ much. Only thing that would possible remain >> slightly different are the details of justifications that must be provided >> and the size of the block to be allocated. >> >> Another thing that I wanted to understand better is the reasoning to >> allocate a significant smaller IPv6 block to a said end-user organization >> given it is not so scarce resource. At least a /40 should be minimal default >> for a end-user (not a /48) and a /32 for any size of ISP. For now my >> personal impression is to create some artificial scarcity in order to have >> different levels of Service Category. >> > > I think it's just a policy residual that is a byproduct of the old separate > fee schedules for end > users and ISPs. ... Glen - Issuance of /48 IPv6 prefixes for end-sites are the result of ARIN registry policy that was developed by this community and heavily informed (as pointed out by Bill Herrin) by the 2001 guidance from the IETF contained in RFC 3177. I will note that since then there has been more nuanced guidance from the IETF in the form of RFC 6177 (2011) that specifically notes that larger issuance should be provided when it makes operational sense – along the lines noted by David Farmer in his reply. > We probably should do away with the distinction between end users and ISPs in > policy since > we've done away with the distinction in fee schedules and even before then > end users could > exercise a one time option to be "treated as an ISP". Like the consolidation > of fee schedules > did it would reduce confusion for new members by simplification. ARIN registry operations follows the policy developed by this community - to the extent that there are different policies for different operational usages, ARIN implements accordingly. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Recommended Draft Policy ARIN-2021-8: Deprecation of the ‘Autonomous System Originations’ Field
On 1 Nov 2022, at 11:10 PM, Owen DeLong mailto:o...@delong.com>> wrote: On Nov 1, 2022, at 19:49, John Curran mailto:jcur...@arin.net>> wrote: You had the option to consolidate to a single billing relationship for all of the resources, but choose not to do so. I had one ORG-ID and one bill. I didn’t change my contracts and suddenly I was faced with two ORG-IDs and twice the billing. Owen - That is correct and not in dispute – because ARIN changed its services & fee structure, you were receiving two distinct bills for two distinct services. It is your characterization of this situation as “double charging” which is inappropriate, as that phrase is clearly understood in commerce to mean billing an entity twice for a given service. This did not occur - you were being charged for your legacy resource registration services (capped per agreement) and being charged for your IPv6 registration services – two distinct services with distinct fees and both under your control. You could continue one service, or both, or neither and your total fees would change accordingly. At no time where you being charged twice for either service, and hence you should avoid from referring to it as “double charging” unless it is your intent to misrepresent others. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Recommended Draft Policy ARIN-2021-8: Deprecation of the ‘Autonomous System Originations’ Field
On 1 Nov 2022, at 9:21 PM, Owen DeLong mailto:o...@delong.com>> wrote: On Nov 1, 2022, at 12:14, John Curran mailto:jcur...@arin.net>> wrote: ... Owen - That was your choice: you could have consolidated into a single billing relationship if you wished or opted (as you did) to maintain distinct billing relationships in which each relationship was billed for services for a distinct and non-overlapping set of resources. No, I didn’t want to be bifurcated in the first place… I was given no choice in that, nor was I given the option of vacating the LRSA in light of this material adverse change. You had the option to consolidate to a single billing relationship for all of the resources, but choose not to do so. I shan’t belabor the point further, but rather reiterate that continued assertion of “double charging” by ARIN (under circumstances where you chose to maintain two distinct billing relationships) can only be seen as an intentional misrepresentation and is specifically prohibited by the mailing list AUP. Best wishes, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Recommended Draft Policy ARIN-2021-8: Deprecation of the ‘Autonomous System Originations’ Field
On 1 Nov 2022, at 3:03 PM, Owen DeLong mailto:o...@delong.com>> wrote: On Nov 1, 2022, at 05:07, John Curran mailto:jcur...@arin.net>> wrote: The “double-charging” that you allege was imposed by the ARIN Board of Trustees was actually self-imposed by you; i.e., you chose to maintain separate billing relationships with ARIN in order to continue benefiting from annual maintenance fee cap applicable to services for legacy IPv4 number resources. This fee cap isn’t applicable to IPv6 number resources nor the registration services fee paid for an organization that consolidates resources under a single registration services plan including non-legacy resources. We will continue to disagree about this, sir. When I made the mistake of signing the LRSA, it was fee per ORG and I maintained a single ORG that had both LRSA and RSA resources and a single billing relationship. When the board pulled the rug out from under that relationship, despite the material adverse change in the relationship, I was not allowed to terminate the LRSA and keep my resources without incurring significant financial penalties and loss of protections that were material to my willingness to sign the LRSA in the first place. Further as a result of that action by the board, ARIN (whether by board decision or by staff choices surrounding the implementation of that decision) chose to bifurcate my organization into two separate organizations for ARIN’s convenience in handling the new billing structure. Owen - That was your choice: you could have consolidated into a single billing relationship if you wished or opted (as you did) to maintain distinct billing relationships in which each relationship was billed for services for a distinct and non-overlapping set of resources. “Double charging” implies being charged twice for the same services and that was never the situation in any case. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Recommended Draft Policy ARIN-2021-8: Deprecation of the ‘Autonomous System Originations’ Field
On 1 Nov 2022, at 12:31 AM, Owen DeLong via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: ... I’ve done it. It got me out of the fee hikes and double-charging that were imposed as a result of the ARIN board’s fee-asco long ago. Owen - The “double-charging” that you allege was imposed by the ARIN Board of Trustees was actually self-imposed by you; i.e., you chose to maintain separate billing relationships with ARIN in order to continue benefiting from annual maintenance fee cap applicable to services for legacy IPv4 number resources. This fee cap isn’t applicable to IPv6 number resources nor the registration services fee paid for an organization that consolidates resources under a single registration services plan including non-legacy resources. This has been already discussed in detail on this list <https://lists.arin.net/pipermail/arin-ppml/2022-April/069518.html>, and alas your decision to maintain two billing relationships had you paying the same amount as all other customers based solely on the number resources in each distinct billing relationship – hence why the the assertion of “double charging” is false and a most inappropriate characterization. Please refrain from such misrepresentation if you wish to continue participation on ARIN’s mailing lists, as the ARIN Mailing List AUP <https://www.arin.net/participate/community/mailing_lists/aup/> specifically prohibits the posting of false or fictitious statements. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Election candidate qualification guidance letters
On 5 Oct 2022, at 1:11 PM, Matt Harris mailto:m...@netfire.net>> wrote: Hey folks, I was just reading over the information related to qualification status for nominees for the various available positions including the NomCom charter which specifies how these statuses are defined for each candidate. This, and other material, references the "guidance letters" which contain the actual criteria used for assessing candidates, but I cannot find a copy of the guidance letters linked to from any of the associated documents nor from the recent emails or blog post related to the upcoming election. It's entirely possible I'm just blind, but in case I'm not mistaken, are these criteria made public? If not, why not? If so, can we perhaps get some links added so that the voting base can take a look at the criteria used to assess candidates and provide these qualification statuses that are referenced in multiple places? Matt - I apologize for the confusion - we often trend a fine line between including too little (versus too much) information in our many announcements to the community. Both the Board and AC Guidance letters to the 2022 Nomination Committee is available from the main ARIN Elections page <https://www.arin.net/participate/oversight/elections/> - the respective links for these document are also attached below for easy reference – The Board Guidance to the 2022 Nomination Committee is available here - https://www.arin.net/vault/participate/elections/board_nomcom_guidance2022.pdf The Advisory Council Guidance to the 2022 Nomination Committee is available here - https://www.arin.net/vault/participate/elections/ac_nomcom_guidance2022.pdf Best wishes, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] Fwd: [arin-announce] Submit Your Questions for Candidates in the 2022 ARIN Elections
Folks - If you have a particular questions for this year’s ARIN Board or ARIN AC candidates, now is your opportunity to submit them for consideration to be used in the upcoming candidate forums. Thanks! /John John Curran President and CEO American Registry for Internet Numbers Begin forwarded message: From: ARIN mailto:i...@arin.net>> Subject: [arin-announce] Submit Your Questions for Candidates in the 2022 ARIN Elections Date: 29 September 2022 at 10:59:15 AM EDT To: "arin-annou...@arin.net<mailto:arin-annou...@arin.net>" mailto:arin-annou...@arin.net>> ARIN Elections are right around the corner, and we are inviting the community to submit questions for this year’s candidates for the ARIN Board of Trustees and Advisory Council. This is your chance to hear straight from the candidates on the issues that most directly impact you and your organization. Selected questions will be answered on Thursday, 20 October, during the ARIN 50 Election Forum. The Advisory Council Candidate Forum will be held from 3:00 to 3:45 PM PT, and the Board of Trustees Candidate Forum will be held from 3:45 to 4:45 PM PT. Do you have a question you’d like the Board of Trustees or Advisory Council candidates to answer? Submit your question(s) anonymously using our online form. You may submit as many questions as you like: https://www.surveymonkey.com/r/2022_Candidate_Questions Submissions will be accepted through 5:00 PM ET on Thursday, 6 October 2021. Once submissions close, we will compile the questions that meet our Mailing List Acceptable Use Policy and Standards of Conduct and share them with the community in survey form. The community will then be invited to rank them in their order of importance or interest. The Candidate Forum moderator will choose from the ranked questions and ask each candidate to answer the selected questions during the Candidate Forum on 20 October. No questions will be taken live from the audience; all questions will be chosen in advance, so make sure to submit your questions now! The Slate of Candidates was announced on 6 September. Before you submit your questions, we suggest that you visit https://arin-elections.net to familiarize yourself with the candidates, their backgrounds, and their views on any issues already covered in the candidate questionnaires. You may also view and submit Statements of Support on this site. These forums are intended to give you, the voter, a better understanding of where each candidate stands on the issues that matter most to you. We believe this will help all our voters make a more informed decision when it comes time to cast their ballots. If you have any questions about ARIN Elections or the Candidate Forums, please contact us at electi...@arin.net<mailto:electi...@arin.net>. We look forward to receiving your questions! Don’t forget: General Members also have the opportunity to engage directly with candidates on the General Member Mailing List. Regards, John Curran President and CEO American Registry for Internet Numbers (ARIN) ___ ARIN-Announce You are receiving this message because you are subscribed to the ARIN Announce Mailing List (arin-annou...@arin.net<mailto:arin-annou...@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-announce Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Revised - Draft Policy ARIN-2022-2: Remove Barrier to BGP Uptake in ASN Policy
It’s perfectly reasonable to discuss the need for specific fee structures to achieve specific number resource policy objectives. To the extent that folks want to have the fees for ASN’s reviewed and possibly changed, I’d suggest that a suggestion be put in the ARIN consultation and suggestion process - <https://www.arin.net/participate/community/acsp/> Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 18 Sep 2022, at 9:13 PM, William Herrin mailto:b...@herrin.us>> wrote: On Sun, Sep 18, 2022 at 8:59 AM Gary Buhrmaster mailto:gary.buhrmas...@gmail.com>> wrote: On Sun, Sep 18, 2022 at 8:03 AM William Herrin mailto:b...@herrin.us>> wrote: I conditionally support this proposal on the condition that there is an accompanying change to the fee schedule such that the second and subsequent AS numbers assigned to a single organization each incur an additional annual fee. I tend to agree here (although, as always, fees are not an issue for policy discussions.) Hi Gary, Well, yes and no. The mechanisms we expect ARIN to use to discourage waste of number resources (and the conditions under which it is appropriate to do so) are within scope for policy. To the extent that money is a major motivator for discouraging waste, I think its discussion in the context of policy is appropriate. I agree that the more specific a discussion of money gets, the less likely it is to be in scope for a policy discussion. But a high-level "money should discourage this activity but not be a barrier to that activity" discussion is reasonable and I think it would needlessly hobble the policy development process to arbitrarily rule anything that touches money to be business process. On Sun, Sep 18, 2022 at 1:16 PM David Farmer mailto:far...@umn.edu>> wrote: I’ll note there is still a $550 Transactional Fee for the issuance of an ASN, I think that is a sufficiently large fee to discourage excessive use of ASNs. Hi David, Fair point. I'll revise my comment to make it more high-level: I conditionally support this proposal on the condition that [it is matched with a] fee schedule such that the second and subsequent AS numbers assigned to a single organization each incur an additional [strike annual] fee. Regards, Bill Herrin -- For hire. https://bill.herrin.us/resume/ ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Availability of the Legacy Fee Cap for New LRSA Entrants Ending as of 31 December 2023
John - You are correct - ARIN continues to provide basic registration services to thousands of non-contracted legacy resource holders (including online updates to your registration, reverse DNS services, etc. ) without fee or contract. That remains an option so long as you don’t wish to use the more advanced services that were developed since, and paid for the ARIN community. Best wishes, /John John Curran President and CEO American Registry for Internet Numbers > On 13 Sep 2022, at 5:05 PM, John Santos wrote: > > $250/year for maintaining the registration of a single class-C network with > an RDNS record that rarely changes, one ORG-ID and 2 POCs that I confirm > every year, but are otherwise unchanged (since the Post Office changed our > ZIP code about 17 years ago) seems excessive. > > I'll keep my free legacy allocation from 1993, thank you. > > On 9/13/2022 4:19 PM, John Curran wrote: >> ARIN will not extend a cap on total annual maintenance fees to those who >> enter an LRSA after 31 Dec 2023 - see attached >> announcement for more details. >> We strongly encourage all legacy resource holders who have not yet signed an >> LRSA to cover their legacy resources to >> consider doing so before 31 December 2023 in order to secure the most >> favorable fees for their ARIN Services as well >> as being able to access ARIN’s more advanced services such as the Internet >> Routing Registry (IRR) and Resource Public >> Key Infrastructure (RPKI) services. >> FYI, >> /John >> John Curran >> President and CEO >> American Registry for Internet Numbers >>> Begin forwarded message: >>> >>> *From: *ARIN mailto:i...@arin.net>> >>> *Subject: **[arin-announce] Availability of the Legacy Fee Cap for New LRSA >>> Entrants Ending as of 31 December 2023* >>> *Date: *13 September 2022 at 2:54:03 PM EDT >>> *To: *"arin-annou...@arin.net <mailto:arin-annou...@arin.net>" >>> mailto:arin-annou...@arin.net>> >>> >>> On 11 October 2007, ARIN implemented the first version of the Legacy >>> Registration Services Agreement (LRSA). This agreement and the fees >>> associated with legacy resources have been modified several times over the >>> past 15 years. The most recent change was in 2022 when ARIN transitioned >>> all customers with IPv4 and/or IPv6 number resources to the same >>> Registration Services Plan (RSP) Fee Schedule which has fee categories >>> based on the total amount of resources held. >>> >>> This most recent change brought those organizations that were issued >>> resources before the formation of ARIN (also known as “legacy resource >>> holders”) into the new Fee Schedule. ARIN also continued providing legacy >>> resource holders a cap on the total amount of maintenance fees due annually >>> – the “annual legacy maintenance fee cap” – that has been offered since the >>> introduction of the LRSA to encourage entry into an LRSA and normalization >>> of these customers’ contractual relationship with ARIN. The “annual legacy >>> maintenance fee cap” is presently set at $150 per year (and will increase >>> by $25 in each subsequent year.) >>> >>> On 4 August 2022, the ARIN Board of Trustees voted unanimously in favor of >>> ending the annual legacy maintenance fee cap applied to legacy resources >>> brought under an LRSA beginning 1 January 2024. All organizations with >>> active LRSA agreements entered prior to 1 January 2024 will continue to >>> have their fees limited for legacy resources covered before that date per >>> the annual legacy maintenance fee cap as noted above. Any new legacy >>> resources brought under an LRSA as of 1 January 2024 forward will fall >>> under the full, normal RSP fees. >>> >>> We strongly encourage all legacy resource holders who have not yet signed >>> an LRSA to cover their legacy resources to consider doing so before 31 >>> December 2023 in order to secure the most favorable fees for their ARIN >>> Services as well as being able to access ARIN’s more advanced services such >>> as the Internet Routing Registry (IRR) and Resource Public Key >>> Infrastructure (RPKI) services. >>> >>> If you have any questions about billing or the 2022 Fee Schedule, please >>> contact 2022f...@arin.net <mailto:2022f...@arin.net>. >>> >>> Regards, >>> >>> John Curran >>> President and CEO >>> American Registry for Internet Numbers (ARIN) >
[arin-ppml] Availability of the Legacy Fee Cap for New LRSA Entrants Ending as of 31 December 2023
ARIN will not extend a cap on total annual maintenance fees to those who enter an LRSA after 31 Dec 2023 - see attached announcement for more details. We strongly encourage all legacy resource holders who have not yet signed an LRSA to cover their legacy resources to consider doing so before 31 December 2023 in order to secure the most favorable fees for their ARIN Services as well as being able to access ARIN’s more advanced services such as the Internet Routing Registry (IRR) and Resource Public Key Infrastructure (RPKI) services. FYI, /John John Curran President and CEO American Registry for Internet Numbers Begin forwarded message: From: ARIN mailto:i...@arin.net>> Subject: [arin-announce] Availability of the Legacy Fee Cap for New LRSA Entrants Ending as of 31 December 2023 Date: 13 September 2022 at 2:54:03 PM EDT To: "arin-annou...@arin.net<mailto:arin-annou...@arin.net>" mailto:arin-annou...@arin.net>> On 11 October 2007, ARIN implemented the first version of the Legacy Registration Services Agreement (LRSA). This agreement and the fees associated with legacy resources have been modified several times over the past 15 years. The most recent change was in 2022 when ARIN transitioned all customers with IPv4 and/or IPv6 number resources to the same Registration Services Plan (RSP) Fee Schedule which has fee categories based on the total amount of resources held. This most recent change brought those organizations that were issued resources before the formation of ARIN (also known as “legacy resource holders”) into the new Fee Schedule. ARIN also continued providing legacy resource holders a cap on the total amount of maintenance fees due annually – the “annual legacy maintenance fee cap” – that has been offered since the introduction of the LRSA to encourage entry into an LRSA and normalization of these customers’ contractual relationship with ARIN. The “annual legacy maintenance fee cap” is presently set at $150 per year (and will increase by $25 in each subsequent year.) On 4 August 2022, the ARIN Board of Trustees voted unanimously in favor of ending the annual legacy maintenance fee cap applied to legacy resources brought under an LRSA beginning 1 January 2024. All organizations with active LRSA agreements entered prior to 1 January 2024 will continue to have their fees limited for legacy resources covered before that date per the annual legacy maintenance fee cap as noted above. Any new legacy resources brought under an LRSA as of 1 January 2024 forward will fall under the full, normal RSP fees. We strongly encourage all legacy resource holders who have not yet signed an LRSA to cover their legacy resources to consider doing so before 31 December 2023 in order to secure the most favorable fees for their ARIN Services as well as being able to access ARIN’s more advanced services such as the Internet Routing Registry (IRR) and Resource Public Key Infrastructure (RPKI) services. If you have any questions about billing or the 2022 Fee Schedule, please contact 2022f...@arin.net<mailto:2022f...@arin.net>. Regards, John Curran President and CEO American Registry for Internet Numbers (ARIN) --- REFERENCE LINKS 11 October 2007 Announcement: https://www.arin.net/vault/announcements/2007/20071011.html ARIN Fee Schedule: https://www.arin.net/resources/fees/ August 2022 Board of Trustees Minutes: https://www.arin.net/about/welcome/board/meetings/2022_0803/ ARIN Services Available to Legacy Organizations: https://www.arin.net/resources/guide/legacy/services/ ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] Fwd: [arin-announce] New ARIN Registration Services Agreement
Updated RSA agreement available. FYI, /John John Curran President and CEO American Registry for Internet Numbers Begin forwarded message: From: ARIN mailto:i...@arin.net>> Subject: [arin-announce] New ARIN Registration Services Agreement Date: 12 September 2022 at 12:56:02 PM EDT To: "arin-annou...@arin.net<mailto:arin-annou...@arin.net>" mailto:arin-annou...@arin.net>> ARIN is pleased to announce the release of an updated combined Registration Services Agreement (the “RSA”) RSA Version 13.0/LRSA Version 5.0 (https://arin.net/about/corporate/agreements/rsa.pdf). This agreement takes the place of RSA Version 12.0/LRSA Version 4.0 and is immediately made available for signature. Further, any signatories of prior versions of the RSA or LRSA that are in good standing are able to update and execute this version of the RSA if they wish to do so. ARIN is committed to removing hurdles to organizations making use of ARIN’s services to the extent reasonably possible. We have updated the RSA several times since its inception; each time, we have incorporated changes to address concerns and comments received from the community. This updated RSA changes one section of the RSA that has been the subject of notable community feedback over the years. The updated RSA removes significant representations from Section 7 and renames the section (previously titled “No Property Rights”) to “Acknowledged Rights To Included Number Resources.” A redline showing the change may be seen here: https://arin.net/about/corporate/agreements/rsav13_changes.pdf. We have not changed the RSA in more than five years; however, we felt that this small change may be helpful to customers considering ARIN’s services, including RPKI and our recently introduced Authenticated IRR. For clarity, this change to the RSA does not impact, nor does it alter, ARIN’s position that Internet Number Resources are not freely-held property. Internet Number Resources constitute a bundle of contractual rights that are created upon issuance of an Internet Number Resource from the registry to a registrant. The original “No Property Rights” section was created at a time when this clear statement was necessary. Since then, the RSA has undergone multiple updates, including the addition of the specified rights granted to a Holder as detailed in Section 2 of the RSA titled “Conditions of Service.” We are hopeful with the release of this updated RSA that organizations will more easily be able to utilize ARIN’s full suite of services. Regards, John Curran President and CEO American Registry for Internet Numbers (ARIN) ___ ARIN-Announce You are receiving this message because you are subscribed to the ARIN Announce Mailing List (arin-annou...@arin.net<mailto:arin-annou...@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-announce Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] IMPORTANT - Deadline Approaching — Make Sure Your Organization is Eligible to Vote in ARIN’s Upcoming Election!
Folks - A very important deadline for participation in this year’s ARIN election is fast approaching. With the changes to ARIN membership that occurred this year, any organization with IPv4 or IPv6 number resources under contact & current on their ARIN fees may request ARIN General Member status, assign a voting contact, and participate in this year’s election. See the message below for further information. FYI, /John John Curran President and CEO American Registry for Internet Numbers Begin forwarded message: From: ARIN mailto:i...@arin.net>> Subject: [arin-announce] Deadline Approaching — Make Sure Your Organization is Eligible to Vote in ARIN’s Upcoming Election! Date: 24 August 2022 at 11:17:26 AM EDT To: "arin-annou...@arin.net<mailto:arin-annou...@arin.net>" mailto:arin-annou...@arin.net>> We hope you are excited to participate in ARIN Elections this October. Please note that a key deadline for the ARIN Elections process is coming up. All organizations who wish to vote in this year’s election must be a General Member in Good Standing before 5:00 PM ET on Monday, 5 September 2022. A General Member in Good Standing is defined as an entity that is current on all annual fees as well as having a valid Voting Contact on record. Only General Members in Good Standing are eligible to vote in ARIN Elections. If you are not sure what type of member your organization is, you may check its status in your ARIN Online account. If your organization is eligible to request General Membership, you can access the General Member request form through the ACTIONS drop down menu. If you are already a General Member, please make sure your account has no overdue invoices on file and that you have designated a Voting Contact in your account before 5:00 PM ET on 5 September. To learn more about how to designate or view your current Voting Contact, visit: https://www.arin.net/participate/oversight/membership/voting/ Don’t forget — General Members may also participate on ARIN’s General Member Mailing List. Subscription to the list is limited to General Members only, as well as Trustees and key ARIN staff, and it is intended for discussion of topics related to the governance of ARIN as well as ARIN Elections. For more information on ARIN’s Elections, including a calendar of important dates, visit https://www.arin.net/elections. To learn more about membership at ARIN, visit https://www.arin.net/membership. Voting in ARIN Elections helps steer the future of Internet number resource policy and Internet governance. We look forward to your organization being able to participate this October. Regards, John Sweeting Chief Customer Officer American Registry for Internet Numbers (ARIN) ___ ARIN-Announce You are receiving this message because you are subscribed to the ARIN Announce Mailing List (arin-annou...@arin.net<mailto:arin-annou...@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-announce Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 9 Aug 2022, at 5:09 PM, Ronald F. Guilmette wrote: > > In message <69ed05b4-afc0-48ea-b466-417b2dab4...@arin.net>, > John Curran wrote: > >> From where I am sitting, and based on my substantial knowledge of ARIN's >> past actions, >> your answer sounds an awful lot like "No, we're not going to do that. We >> have better >> things to do." >> >> Actually, my meaning is absolutely clear based on plain language usage - >> We _will_ endeavor to look into such situations and correct where possible > > Great! When? > > In October of 2020, a spokesperson for ARIN was quoted by journalist Brian > Krebs as > saying that the matter of the long-ago dissolution of Centauri Communications > (CENTA-3) would be investigated: > > > https://krebsonsecurity.com/2020/10/the-now-defunct-firms-behind-8chan-qanon/ > > It is now August, 2022, and the evidence of ARIN's commitment to > investigating such cases > (or rather, the utter lack thereof) is now crystal clear and evident for all > to see. A > full 21 months later and the ARIN staff has done absolutely nothing to either > investigate > or action this case in any way. > > This isn't ambiguous. We have the reciepts. ARIN was informed. ARIN said > it would > investigate. ARIN did nothing. ARIN lied. Incorrect. > And yet here you are, repeating the lie yet again, and still falsely claiming > that ARIN > "_will_ endeavor to look into such situations and correct where possible". > > The problem is that ARIN won't. The evidence is clear. ARIN just won't. ARIN did investigate - see below. > (I was wrong in my prior email to suggest that ARIN would give a low priority > to the task > of reclaiming number resources from dead companies. In fact, the evidence is > clear that > ARIN has given and will give this effort ZERO priority... or maybe even a > negative > priority.) > >> And finally, could you please explain, John, how your reluctance to >> reclaim those >> valuable IPv4 assets from dissolved and now non-existant corporate >> entities comports >> with ARIN's basic mission to be good shepherds of ARIN's finite and >> limited resources? >> Because I'm not seeing it. >> >> >> There's no reluctance on ARIN's part to researching any reports submitted >> and taking >> appropriate action - including "reclaim(ing) those valuable IPv4 assets >> from dissolved >> and now non-existant corporate entities" > > You are prevaricating John, and the facts regarding Centauri Communications > demonstrate > otherwise. ARIN was informed about this case over 21 months ago, and an ARIN > spokesperson > at that time confirmed to Brian Krebs that this case would be investigated. > However as > anybody who knows how to use the ARIN WHOIS server can plainly see, > absolutely nothing > has changed with respect to this long-dead entity and/or the several IPv4 > blocks that > were and are registered to it (and that are now being squatted on by > _somebody_) in all > of the past 21 months. > > I remind you also that official California State records indicate that this > company has > been dead and dissolved for TEN YEARS. > > Would you care to explain John? Please note that the company in question is _suspended_ not dissolved. As previously noted, there is a significant difference – ARIN does not act against organizations solely on the basis of their corporate status being suspended, as it can easily be the result of tax filing delay, etc. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 9 Aug 2022, at 5:10 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: In message <7eacaf7e-1f93-42fe-828a-5f9ca9a59...@arin.net<mailto:7eacaf7e-1f93-42fe-828a-5f9ca9a59...@arin.net>>, John Curran mailto:jcur...@arin.net>> wrote: If you find a Whois entry that reflects resources assigned to a clearly dissolved entity, feel free to report it here: https://account.arin.net/public/whoisinaccuracy/report (Include sufficient detail to facilitate our verification of this status) We will endeavor to look into such situations and correct where possible - considering that (as you did above) we have limited resources that must be prioritized across many activities. My compliments John. I literally cannot recall the last time I encountered such a well-crafted and well-phrased non-committal non-responsive non-answer. From where I am sitting, and based on my substantial knowledge of ARIN's past actions, your answer sounds an awful lot like "No, we're not going to do that. We have better things to do." Actually, my meaning is absolutely clear based on plain language usage – We _will_ endeavor to look into such situations and correct where possible .. Is it true that, as shown here: https://www.arin.net/resources/guide/ipv4/waiting_list/ there are currently approximately 407 different organizations that are awaiting the availability of IPv4 free pool resources, and that some of these have been waiting in the ARIN Wait List for very nearly seven full months for IPv4 block availability? Indeed. Would you agree or disagree with the clearly evident fact that the organization denoted in the ARIN WHOIS data base via the handle CTC-211 is currently the registrant of the equivalent of an entire /17 IPv4 block, and that this same organization is and has been listed in public records available on the Colorado Secretary of State's web site as having been formally dissolved, by the State, in a formal legal action, nearly four full years ago? Would you agree or disagree that whoever is using those several IPv4 blocks that remain assigned to that organization (CTC-211) after it entered into an RSA contract with ARIN *and* after that organization was legally dissolved by the State of Colorado has no legal right to use the space, and that thus, whoever is doing that now is in fact simply squatting on that /17 worth of valuable IPv4 space? I have not reviewed the available information, as ARIN has a very able Registration Services Team that will handle such with appropriate diligence (if a report is submitted...) Would you agree or disagree that if an entire /17 worth of IPv4 address space were returned to the ARIN free pool, that this could be used, eventually, to satisfy the pending requests of at least thirty two (32) different live and deserving organizations that are currently languishing patiently on the ARIN wait list? That’s a logical conclusion in light of the maximum approved prefix sizes for issuance under the present waiting list policy. And finally, could you please explain, John, how your reluctance to reclaim those valuable IPv4 assets from dissolved and now non-existant corporate entities comports with ARIN's basic mission to be good shepherds of ARIN's finite and limited resources? Because I'm not seeing it. There’s no reluctance on ARIN’s part to researching any reports submitted and taking appropriate action - including “reclaim(ing) those valuable IPv4 assets from dissolved and now non-existant corporate entities” (At the present time, I only see reluctance on your part to reporting such entities to ARIN.) It is clear from your prior answer, quoted above, that it is your view is that reclaiming scarce assets from dead and defunct corporate entities so that ARIN can redistribute them to live and deserving organizations is, and properly should be "low priority" for ARIN staff, like as if you all had something better or more pressing to do. ARIN has not been directed by the community in any policy to embark on a general review of all entities in the ARIN database looking for “dead and defunct corporate entities” - so if this is what you are suggesting, then you are correct - such a task would be very low priority indeed. If you are referring to researching those entities reported to ARIN and taking appropriate action, then you would be incorrect – ARIN will pursue such reports as they are received. Please explain this to me then. What job is higher priority for you and for the ARIN staff than actively managing the scarce resources that have been entrusted to your care in a way so as to insure that worthy organizations can obtain those resources in preference to illegal squatters? Are you and the entire ARIN staff all just too busy making reservations for your upcoming all-expense-paid trips to Hollywood, California for the ARIN 50 meeting in October to allow you folks time to intelligently ad
Re: [arin-ppml] Deceased Companies
On 7 Aug 2022, at 11:11 PM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: It is positive that many of these legacy holder returned some of their unneeded IPv4 resources in the past. However I personally believe it is something negative that there is still a fair amount of these addresses unused and not even announced to the DFZ as if they were waiting for some big Internet event to happen. It is not possible to infer that resources are unused simply from the fact that they are “not announced to DFZ”... I really don't mind Legacy Holders to keep addresses that were assigned to them ages ago as long they have a justification for using them. The ARIN community has never developed or adopted any policy to the effect that legacy resources holders must justify their resources in order to keep them, so this should not be a matter of concern. In the other hand I am unable to believe any organization in the entire world that is not a Telecommunications or a Hosting Company is able to technically justify more and a single /8. I will note that very large organizations have networking needs that rival or even exceed that of many telecommunications firms. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 5 Aug 2022, at 4:48 PM, Ronald F. Guilmette wrote: > ... > Although I have no objections whatsoever to giving my best effort to drafting > and defending a policy proposal on the topic of dissolved resource-holding > entities, I am well aware that the policy adoption process could possibly > take quite some months. In the interm. what, if anything, does the CEO feel > either can or should be done, by staff, with respect to such dissolved > entities > that may come to staff's attention? Obviously, having clear and ratified > policy > guidance in place is optimal, but I am not persuaded that the current absence > of such clear guidance entirely precludes ARIN staff from appropriately > actioning > such cases on its own authority, consistant with ARIN's overall mission of > being > good shepherds of limited resources. Ronald - If you find a Whois entry that reflects resources assigned to a clearly dissolved entity, feel free to report it here: https://account.arin.net/public/whoisinaccuracy/report (Include sufficient detail to facilitate our verification of this status) We will endeavor to look into such situations and correct where possible – considering that (as you did above) we have limited resources that must be prioritized across many activities. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies
On 6 Aug 2022, at 10:00 PM, Steven Ryerse mailto:srye...@eclipse-networks.com>> wrote: ... If this community wants more resources, the more obvious place to find them isn't some relatively small block held by an organization or individual that might be deceased, this community could try and convince the DoD to release some portion of their very large /8 assignments. That could be fertile ground. Who knows how many IPv4 addresses they are actually using and need. I've never heard of it happening but it wouldn't surprise me if ARIN has quietly discussed this possibility with the DoD as some point. We wouldn't hear about it unless resources were actually released. Already happened (more than a decade ago): the US DoD, BBN, Stanford, Interop, etc. all returned some of their unneeded IPv4 resources after being approached by ARIN – the address space was returned, held for a period, and then issued by the policies in place at that time. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] ARIN actions regarding address blocks with no valid POCs (was: Re: Deceased Companies?)
> On 6 Aug 2022, at 10:02 PM, Ronald F. Guilmette > wrote: > ... > Even ignoring the rather colorful and vivid imagery of the above statement, > I would suggest that, as a purely pratical matter, it would be highly > inadvisable for ARIN to make any effort to reclaim any of the some 175+ > million IPv4 addresses currently assigned to the United States Department > of Defense. Many US Government agencies, including the US Department of Defense, are already ARIN members with their number resources under a registration services agreement. I do believe that they will always remain in good standing (and most fervently wish that to be the case since having to deal with reclamation might indeed be a tad challenging…) FYI, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 5 Aug 2022, at 3:48 AM, Ronald F. Guilmette wrote: > > In my my immediately prior email on this topic I neglected to mention three > important and entirely relevant points. > > First, I should clarify the reason for my interest in this topic of dead > resource-holding organizations. As some but not all here may be aware, > I personally have invested quite a lot of time and effort over the years > in finding and exposing Bad Actors on the Internet. In the many years > that I have been doing this entirely uncompensated work, I A noble endeavor indeed. > ... > Second, with respect to the rather superficial legal analysis included in > my prior email, that analysis was and is hampered somewhat by a key point > of ignorance on my part. Specifically, it is unclear to me if ARIN staff > (or policy) requires that resource-holding entities sign and return a fresh > new RSA... presumably having the latest and greatest RSA version number... > at every point in time when such an entity has requsted (or is assigned) > some new allocation of number resources. Can any kind soul enlighten me > on this point? If one engages with ARIN to obtain new resources (or make any similar substantial change to their number resource holdings), ARIN will seek entry into the current RSA if the present agreement is more than two versions back. We don’t update the RSA very often, but feel that some leeway in this regard is still operational sound and helps reduce administrative overhead of working with ARIN. > ... > > Third and lastly, I am compelled to express my profound dismay that ARIN > staff appears to be playing a somewhat elaborate game of "hide the ball" > when it comes to making available older / non-current versions of the RSA. > Reasonably diligent efforts to find these older RSA versions, by me, and > on the ARIN web site, were consistantly met with either web site "not > found" errors or by redirections to the current and latest version (12.0) > of the RSA, which is not at all what I was seeking. > > Needless to say, the inability to obtain copies of older versions of the RSA > makes it literally impossible to form any reasoned opinion about what various > organizations, dead or otherwise, may or may not have been contractually > bound to do or not do. > ... > I can well understand why ARIN staff and management may wish to have the > average Joe Schmo looking only at the most current version of the RSA, > but deliberately making older versions of this key document unavalable, > even to researchers, is unacceptable and should be rectified forthwith. This is not intentional (nor different than the practices of most organizations) but rather the desire to minimize confusion and potential for parties using the wrong version when dealing with ARIN. However, it should be relatively easy to provide a suitable reference archive, and we will endeavor get such setup shortly for that purpose. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 5 Aug 2022, at 2:39 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: Although I am greatly appreciative of Ted's comments, which appear to be supportive of the primary point that I most recently attempted to make here, I am obliged to point out that the example of the 199.248.255.0/24 block, and ARIN's seeming reluctance to reclaim it, *does not* actually support the point that I have attempted to make here most recently. for one very glaringly obvious reason: RegDate:1994-10-11 199.248.255.0/24 is unambiguously a legacy block. Thus, ARIN may or may not have in hand either a signed RSA or a signed LRSA that is relevant and applicable to this block. For the sake of argument, let's assume that it doesn't. Other people may reasonably disagree with me, but I personally am at least somewhat sympathetic to the various legal assertions and bold claims that have been made by various IPv4 legacy registrants, over time. I am also at least somewhat sympathetic to ARIN's understandable reluctance, if any, to sally forth and do battle in the courts over such legacy-related claims. Alas, there’s very little evidence that legacy resource holders (being parties that lack any written agreement with ARIN) have any magical ability or right that would preclude ARIN operating its registry exactly as directed by community policy (including entries held by legacy resource holders), but I recognize there are some who may feel otherwise. ARIN actually have zero reluctance when it comes to defending the community’s right to establish apply policies applicable to the entire registry, and we do quite vigorously defend the same in court without hesitation. (Any reticence you see regarding the establishment of new policy requirements applicable to legacy resource holders is simply driven out of the desire to be respectful to all parties with resources in the registry and desire that any such policy changes be based out of a clearly articulated policy need of this community. We have done many such changes in the past that are applicable to the entire registry including legacy resource holders – this includes addition of the abuse contact, number resource resource review section, POC validation, etc.) ... In fairness, I must apologize to John Curran, to the entire ARIN staff, and to everyone here if my questions relating to this topic of dead companies may at times have seemed somewhat accusatory in tone. Upon reflection, I must now say that any apparent inaction, on the part of ARIN staff, with respect to such deceased entities, although somewhat frustrating to me personally, is likely entirely understandable. It would be entirely unfair to lay any blame for what would appear to be a lack of action relating to such cases at the feet of the ARIN staff. I mean after all, they are but the servants of the ARIN community and the ARIN membership, and they cannot fairly be blamed if the community and the membership have given them absolutely zero in the way of clear guidance on what, if anything, they should do about dead resource-holding organizations. Rather, if there is any blame to be laid for inaction when it comes to dead resource-holding organizations, then I think that it can only fairly be assigned to the ARIN community and the ARIN membership. The community and the membership should have addressed this issue long ago, and having failed to do so, the community and the membership should do so now. Better late than never. It is altogether clear to me what must, at the very least be done. At the very least, the community and/or the membership should give clear guidance, immediately, to John Curran and the ARIN staff regarding what they should do when they become aware, VIA ANY MEANS OR CHANNEL, of the dissolution of any resource-holding entity that has ever signed an RSA agreement with ARIN. ... So, it is clear, to me at least, what must, at a minimum, be done. The question remains of what process should be used to achieve it. Should this be a "consultation" or should it instead be a formal policy proposal? I would suggest a formal policy proposal; you can find additional information on submitting such here – https://www.arin.net/participate/policy/pdp/appendix_b/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] ARIN actions regarding address blocks with no valid POCs (was: Re: Deceased Companies?)
On 4 Aug 2022, at 5:01 PM, Ted Mittelstaedt mailto:t...@ipinc.net>> wrote: On 7/26/2022 12:50 PM, John Curran wrote: if such a case were brought to our attention and the resources were not being used, we’d revoke. If they were in use, we’d try to reach the party using them first (as there may be a legal successor after all and we just didn’t identify that properly.) I'm jumping in a bit late but this is sheer baloney. (I'd use a stronger word if I could) I have used the block 199.248.255.0/24 previously on this list in the past as an example of ARIN's nonsense when it comes to reclaiming old blocks and to embarrass John Curran when he claims ARIN is cleaning house. This block is NET-199-248-255-0-1 It has 2 POCs on it that state right in the ARIN database that they are currently unvalidated. So already it is in violation of the NRPM … Ted - To my knowledge, the Number Resource Policy Manual (NRPM, i.e. https://www.arin.net/participate/policy/nrpm/ ) does not presently provide for ARIN performing reclamation of address blocks assigned to an organization that has no valid POCs – it provides that such organizations "will be unable to access further functionalities within ARIN Online” and cannot be receiving organization for a reallocation or detailed reassignment. (NRPM 3.6.5 and NRPM 3.7 respectively) If you’d like ARIN to take particular action on address blocks with no valid POCs, please propose policy specifying the actions for community consideration and potential adoption. You can find more information on submission of policy proposals here - https://www.arin.net/participate/policy/pdp/appendix_b/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 26 Jul 2022, at 8:27 PM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... And in general, I believe ARIN _does_ know all of that, except when it comes to deceased entities, where it appear to be blind as a bat. Ronald - Deceased entities generally don’t pay their renewal invoices. which then results in revocation of the associated number resources… (and no need to track them) Your stream of hypothetical situations has predominantly been regarding deceased entities that somehow have still manage to have their ARIN invoices paid on an ongoing basis - not likely to be a very common occurrence with truly defunct entities. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 26 Jul 2022, at 4:32 PM, Ronald F. Guilmette > wrote: > … And indeed, if my > browser's search function is working properly then it would appear that > neither the > word "death" nor the word "dissolution" appears anywhere in the entire NRPM. > Would > you agree that these terms and/or terms having similar meanings are not > mentioned at > all, either in the NRPM or in the RSA? Correct - there are many words not referenced in the Number Resource Policy Manual. > John you _seem_ to be agreeing that that if a corporate entity that was a > member and > resource holder has become dissolved by default (or if natural person which > was a > resource holder has died) and if the relevant resources are still in use, > that ARIN > would, quite reasonably, attempt to make contact with the current user of > said resources > and that ARIN would ask that current user (or those current users) to provide > some > legal documentation which would legally and definitively indicate the > identity (or > the identities) of the heirs, successors, or assigns of the now-former > member. Is > that a correct reading of your statements, or am I inferring too much? No, you are not inferring too much – your statement is correct regarding resources reported to ARIN that were issued to an organization that has since dissolved. > And are you also asserting that in the absence of any timely production of > such > documentation, ARIN would reclaim all relevant number resources and terminate > the > associated (now defunct) membership? Also correct – we do use an extra degree of caution when it comes to resources that are actively routed; it doesn’t change the outcome but does provide another lead to pursue and potentially evidence of actual customers that might be impacted. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 26 Jul 2022, at 3:05 PM, Ronald F. Guilmette > wrote: > > In message <050367fd-7090-4f98-9c34-2904f1129...@arin.net>, > John Curran wrote: > >>> Section 8.2. of the NRPM covers "Mergers, Acquisitions, and >>> Reorganizations". The policies >>> and procedures that are to be applied in all of those situations are quite >>> clearly set >>> forth there. Section 8.2. of the NRPM quite clearly *does not* cover >>> dissolutions. >>> Please provide a straight answer to the question I did ask, which related >>> to dissolution >>> situations. >> >> It appears to be a reorganization of the failing operation from an LLC to >> now operating under >> under a registered legal name instead. > > You are still evading the question John. > > I provided a straightforward hypothetical of a small business that was > validly operating > within the state of California, which was formerly (a) registered as an ARIN > member, and > which (b) was the registrant/Holder of ARIN resources, and which (c) either > by deliberate > choice of the owner(s) or by defaulting on its legal obligations to the > State, became > dissolved as a legal entity, i.e. it ceased to exist as a legal entity. > > What is the legal basis for you to claim that such an entity "appears to be a > reorganization"? I did not provide a legal basis; I noted the basis in ARIN number resource policy. >>> You are being deliberately obtuse and evading the question. If the >>> hypothetical TMBBATS LLC >>> goes belly up, then when will the Registration Services Helpdesk, or any >>> other part of ARIN >>> even notice this fact and take some action (i.e. ANY action)? After 1 >>> year? After 2 years? >>> After 10 years? Ever? >> >> No, not unless specifically brought to the attention of ARIN. Note that >> such conditions, >> as we have discussed here, are sometimes transitory and may be cured or >> reinstated, >> so absent clear direction in policy we will not monitor and/or reclaim under >> a lapse in >> regisration. > > You have just contradicted yourself within the space of two sentences John. > First you > make a rather vague and entirely non-commital comment which you apparently > hope will > give us the vague impression that ARIN might actually DO SOMETHING if a dead > company > which is a member and resource holder is "specifically brought to the > attention of ARIN". > And then, in the very next sentence, you appear to assert that ARIN won't do > damn thing > about any such cases, EVEN IF they are "specifically brought to the attention > of ARIN", > because you have been given no explicit policy guidance that would apply in > such a case. > > So? Which is it? Please get down off the fence John. It must be rather > uncomfortable > for you sitting on that. We would evaluate it for possible reclamation, but do so in a very conservative manner (as I indicated in the previous response) > So? Which is it? > > I will restate the question yet again in an effort to try to further reduce > the chances > for another non-responsive answer. I was responsive; alas, I cannot help that you apparently did not like the answer. > If a given (now former) corporate entity was dissolved, either voluntarily or > otherwise, > by the competent legal authority that oversees such matters within its > incorporation > jurisdiction, and if all available evidence indicates that this is NOT merely > a > "transitory" situation, but rather one that has gone on for many years, > continuously, > and if this member is "specifically brought to the attention of ARIN" (your > words) > then what, if anything, will ARIN do, right now, today, in such a case? > > Assume for the sake of argument that whoever or whatever ARIN staff may > _feel_ is the > rightful heir, assign, or successor of the now dead company is utterly > unresponsive > to any and all outreach from ARIN. What will ARIN do in such a case? If the corporation was voluntarily wound down (as opposed to simply failing to filing the required annual reports as stated your prior hypothetical), and there is no responsive contact, then we would proceed with revocation. Note that “no responsive contact” means just that - not just their apparent heir, but also no evidence of operational use. > Please provide a clear answer to this question John. Just mumbling some > vague musings > about "working with the member to try to rectify/cure the situation" is not > what > I'
Re: [arin-ppml] ARIN Guidelines, regarding use in ARIN region, curious question
On 26 Jul 2022, at 12:45 PM, Michael Peddemors mailto:mich...@linuxmagic.com>> wrote: Noticing more cases of IP Assignments for a 'company' with a North American presence, that simply reassigns/reallocates portions of their IP assignments to offshore and foreign companies with no North American presence at all.. How does the intent of ARIN guidelines apply, when a 'shell' company is formed to provide IP ranges for companies outside of the ARIN region? Michael – The theory is (as laid out in NRPM section 9) that the organization must have "a real and substantial connection with the ARIN region” If you are seeing circumstances where this is likely is not the case, please report it - https://www.arin.net/reference/tools/fraud_report/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 26 Jul 2022, at 12:42 AM, William Herrin wrote: > ... > We've gotten way into the weeds here so I'll bring it back to this: > it's dubious whether or not ARIN has the authority to make and enforce > a change to the policies that would have a materially adverse impact > on the legacy registrations. You say yes. I say no. Until a judge says > yes or no we're both guessing. > > What *is* certain is that ARIN has not attempted to do so in the > quarter century it has existed. Not even once. There have been > proposals but none have proceeded to adoption or implementation. Many > changes adversely impacting RSA registrations. None adversely > impacting legacy registrations. Actually, I’m not aware of changes that particularly adversely impact registrations of either type, but that makes perfect sense as the registry policies are not set by ARIN, but rather by the ARIN community – again, this ability for the community to establish these policies is the entire reason for the change to a "commercially based, self-regulating entity.” (NSF’s language) > And because I can't resist one last dig - I observe again that ARIN > has studiously avoided putting any judge in the position to decide > the question. Bill – we routinely go to court over precisely such matters, but the “problem" is that the we are consistently successful in these proceedings, and face opposition that inevitably settle rather than carrying a losing hand to a final adverse judgement. We’ve actually had the matter before many judges, and have never been ordered to do anything other than operate the registry per the number resource policy as developed by this community – this has been the consistent outcome throughout both civil and bankruptcy proceedings. Yes, we do settle cases, but only when that basic principle is upheld. Rather, it is your position (that for some reason legacy resource holders do not have meet the policies developed by the ARIN community) that has never been upheld in any orders granted – and not for lack of trying. Alas, those who seek such an outcome have never been successful in arguing its merits, and instead consistently end up settling with orders that recognize ARIN’s ability to operate the registry according to the community-developed policy, including the application of the policy to their address blocks. ARIN simply doesn’t settle absent those terms, as it is a simply a fundamental principle of our inception. Mind you, this is _easily_ solved - simply take any of your bona fide objections to the policy developed by ARIN community; e.g., that which adds the “abuse” contact, or the policy which establishes annual POC validation (or any other policy language that’s already being applied to your legacy address blocks today) and pursue that elusive right that you assert you have: i.e. the right to force ARIN to maintain your legacy resources in the ARIN registry independent of the community-developed policy. (Note, until such time as your purported right survives the inside of a courtroom, I’d suggest continued participation in the ARIN policy development process on this mailing list, as the policies that are developed and adopted by this community will most certainly continue to apply to your legacy resources…) Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 10:18 PM, William Herrin wrote: > > Still the same as when we had this discussion 10 years ago when you > were, to use your words, "well aware of" it. > > https://lists.arin.net/pipermail/arin-ppml/2012-June/058754.html Bill - Yes, I remain well aware of it, but alas it was the NSF that directed the transfer of the tasks and database to ARIN – there is nothing present in their direction to suggest your postulated limitation, and the NSF press release is remarkably clear that the community will be able to set policy for the management of the registry database. You may believe that you have some encumbrance on the ARIN registry database that allows you to operate outside of the community-developer policy, but absent some agreement to that effect I’d advise against doing so as ARIN will continue to operate the registry per the community-developed policy for all registry entries, legacy included – as announced by NSF at ARIN’s formation. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 5:42 PM, William Herrin wrote: > > On Mon, Jul 25, 2022 at 2:28 PM John Curran wrote: >> "Creation of ARIN will give the users of IP numbers (mostly Internet service >> providers, corporations and other large institutions) a voice in the >> policies by which they are managed and allocated within the North American >> region.” >> >> Internet Moves Toward Privatization, National Science Foundation, June 1997 >> <https://www.nsf.gov/news/news_summ.jsp?cntn_id=102819> >> >> If you’re a legacy resource holder, it’s best to recognize that ARIN’s >> formation was precisely so >> that you could gain the ability to participate & gain a voice in policy >> development for management >> of the registry (as opposed to having it set by some US government >> contractor or bureaucrat.) >> i.e. it’s a lot less murky than you suggest. > > Hi John, > > Respectfully, you're dissembling here, offering a claim that's a half > truth at best. To secure the community's cooperation at the time, ARIN > repeatedly promised that it would not apply any new policies to the > legacy registrations absent the legacy registrants' consent. We can > both find the aspirational documents surrounding ARIN's creation but > the legal documents at no point transfer to ARIN the authority to > alter the preceding grants. Bill - Actually, the “policies by which they are managed” means precisely that - the registrations shall be managed accordingly policies developed by the community. To the extent that you have any information or historical documents that somehow imply that changed policies “would not apply”, could you please post such asap? That would represent a fairly large difference in perspective, and would imply that policies could never be changed for any existing registrations (certainly not the situation anywhere else in the Internet number registry system) Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 5:50 PM, Ronald F. Guilmette > wrote: > > In message <91f20ecc-6de8-4de7-822c-b3436465e...@arin.net>, > John Curran wrote: > >>> So I ask again, where is the justification, either in legal principals or >>> in the >>> actual text of the RSA that says that George retains (or obtains) _any_ >>> interest >>> in the /24 upon the death of George's LLC? The way I read the plain >>> language of >>> the RSA, all claims, rights, and titles to the /24 must necessarily pass >>> back to >>> ARIN upon the death of the LLC, if for no other reason, then at least for >>> the >>> obviious reason that "The Holder" no longer exists and thus can no longer >>> pay the >>> annual fees. >> >> Wonderful logic. I'll note that telecommunications companies routinely >> consolidate, and >> that it is quite possible that invoices will paid from an account other than >> one that signed >> the ARIN agreement. (Given how some organizations are about updating their >> merger >> records, any other position would be irresponsible...) > > This is a clear evasion of the question John. I am not evading the question - you said " if for no other reason, then at least for the obviious reason that "The Holder" no longer exists and thus can no longer pay the annual fees.” I noted, in reply, that there is very little relevance as to who pays the annual registration fees, and such fees are frequently paid by entities that are not the same legal entity (it’s unclear that ARIN would even know if paid out an account owned by a different legal entity.) > Where is the justification, either in legal principals or in the actual text > of the RSA > that says that George retains (or obtains) _any_ interest in the /24 upon the > death of > George's LLC? Reorganization per NRPM 8.2, in the case where there is no dispute, an RSA will be entered, and the recipient "provides evidence that it has acquired the assets that use the resources to be transferred from the current registrant." > Section 8.2. of the NRPM covers "Mergers, Acquisitions, and Reorganizations". > The policies > and procedures that are to be applied in all of those situations are quite > clearly set > forth there. Section 8.2. of the NRPM quite clearly *does not* cover > dissolutions. > Please provide a straight answer to the question I did ask, which related to > dissolution > situations. It appears to be a reorganization of the failing operation from an LLC to now operating under under a registered legal name instead. > You are being deliberately obtuse and evading the question. If the > hypothetical TMBBATS LLC > goes belly up, then when will the Registration Services Helpdesk, or any > other part of ARIN > even notice this fact and take some action (i.e. ANY action)? After 1 year? > After 2 years? > After 10 years? Ever? No, not unless specifically brought to the attention of ARIN. Note that such conditions, as we have discussed here, are sometimes transitory and may be cured or reinstated, so absent clear direction in policy we will not monitor and/or reclaim under a lapse in regisration. > The evidence that I am looking at confirms that ARIN is not lifting a finger > to clean > the stables of all of the dead and defunct resource holding members, ever. That is correct (at least under present policy...) > As much as you would like to distract from that central fact by injecting > irrelevancie about > mergers and/or the wonderful helpfulness of Registration Services Helpdesk, > reality is still > reality, and if you had anything positive to say about ARIN's approach to the > problem > of dead companies cluttering up your books then you would have said it by > now, rather > than just trying to change the subject. I was not trying to change the subject, but rather pointing out that if ARIN’s RSD can help a customer retain their number resources in accordance with policy, that’s what will happen. You might not like an ancient lapsed corporate registration being recognized and allowed to transfer to a new legal entity operated by the same party, but this is not foreclosed by policy particularly where it concerns number resources that remain in use by the same assets” Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 25 Jul 2022, at 4:58 PM, William Herrin mailto:b...@herrin.us>> wrote: ... That gets murky but the bottom line is there's no clear grant of authority for ARIN to make unilateral changes to legacy database while there is a clear assignment of responsibility to indefinitely operate that database as a condition of taking over the InterNIC function from the U.S. government. Bill - ARIN making unilateral changes on an ad-hoc basis? I certainly would hope not. However, if you are referring changes made accordingly to the policies established by the community, that’s an entirely different matter – and actually fundamental as to why the transition to ARIN – "Creation of ARIN will give the users of IP numbers (mostly Internet service providers, corporations and other large institutions) a voice in the policies by which they are managed and allocated within the North American region.” Internet Moves Toward Privatization, National Science Foundation, June 1997 <https://www.nsf.gov/news/news_summ.jsp?cntn_id=102819> If you’re a legacy resource holder, it’s best to recognize that ARIN’s formation was precisely so that you could gain the ability to participate & gain a voice in policy development for management of the registry (as opposed to having it set by some US government contractor or bureaucrat.) i.e. it’s a lot less murky than you suggest. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 25 Jul 2022, at 4:28 PM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... I personally believe that ARIN has no legally enforcable obligations to any party that it has no explicit contract with. Ronald - Alas, that’s likely true, but also must be reversed. It is those without agreement who must show that ARIN has some obligation to manage our registry in the manner that as they wish… quite a tall order for a party with no contract, particular given that we were formed to manage it accordingly to the community’s wishes. ARIN’s willing to provide basic registry services without contract or fee, but we have yet to see any party present an obligation enforceable against ARIN for how we operate the registry. (ARIN has quite a few obligations to its members and contracted customers, and they govern how the registry is administered.) Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
Paul - Let’s start over here – 1. You (and your son) do not need to worry about revocation of your existing blocks due to expressing views on the mailing list – everyone is allowed to express their views so long as they stay within the Acceptable Use Policy (basically be on good behavior - https://www.arin.net/participate/community/mailing_lists/aup/) 2. You reference “routing” and "root servers" as things that ARIN controls - that’s really not the case – we simply operate a registry of IP address blocks. 3. I have enormous respect for your right to be an Old Angry Man (and personally aspire to get to that status myself someday :-) 4. ARIN operates a registry database that was directed to be transferred to ARIN by the US Government/NSF, and in the process of our formation ARIN agreed to operate it according to policies set by this community that are developed via an open and transparent process. 5. To the extent that you want to chat about any of the above, feel free to reach out to me at any time: my mobile number is +1 617 512 8095. (It might be possible to walk through some of this orally in a more efficient manner.) Thanks and best wishes, /John John Curran President and CEO American Registry for Internet Numbers On 25 Jul 2022, at 4:08 PM, Paul E McNary via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: ARIN controls the root servers for this region do they not. Without the root servers nothing gets routed. That is a part of the number resources ARIN made commitments to maintain for all resources that had been allocated. And yes I was well alive before Al Gore invented the Internet. :-) From: "pmcnary" mailto:pmcn...@cameron.net>> To: "pmcnary" mailto:pmcn...@cameron.net>> Cc: "Matthew Petach" mailto:mpet...@netflight.com>>, "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 3:05:35 PM Subject: Re: [arin-ppml] Deceased Companies? John My Son is sitting here telling me to Shut the F*** up before you revoke our IP Number resources. So since I am semi-retired, I should do as he says Just an OLD ANGRY MAN. From: "pmcnary" mailto:pmcn...@cameron.net>> To: "pmcnary" mailto:pmcn...@cameron.net>> Cc: "Matthew Petach" mailto:mpet...@netflight.com>>, "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 3:02:56 PM Subject: Re: [arin-ppml] Deceased Companies? John you have repeatably told me I would risk revocation if I obtained a legacy IP block and tried to clean up the registration. You have now changed you mind and I would no longer have to worry if I obtained a legacy IP block from a friend? I here you speaking out of both sides of your mouth. From: "arin-ppml" mailto:arin-ppml@arin.net>> To: "Matthew Petach" mailto:mpet...@netflight.com>> Cc: "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 2:58:21 PM Subject: Re: [arin-ppml] Deceased Companies? I think we are talking about number resources here not the individual numbers. Predecessor entities (pre ARIN) made commitments for the "Number Resources" that were allocated. ARIN assumed those responsibilities and commitments and agreed not to alter them. ie. continue to route "all" number resources that had been previously assigned by Pre-ARIN entities. ARIN keeps trying to stop honoring or threaten to stop honoring these agreed to commitments they made. From: "Matthew Petach" mailto:mpet...@netflight.com>> To: "pmcnary" mailto:pmcn...@cameron.net>> Cc: "William Herrin" mailto:b...@herrin.us>>, "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 2:46:29 PM Subject: Re: [arin-ppml] Deceased Companies? Oy vey. We've had this discussion before. You can't lay a property claim to a number. Google can't "buy" the number googol, and charge people a license fee to use it every time they count that high. I can't "own" the number "pi" and charge everyone who tries to make a circle using it a licensing fee. I don't "own" my telephone number, and can't sue phone spammers for spoofing it when they robocall other people. IP addresses are just binary numbers. That's it. You can't own numbers. All those networks that ran out of RFC 1918 space and were squatting on government blocks? Not guilty of theft, because the addresses aren't property: https://www.arin.net/blog/2015/11/23/to-squat-or-not-to-squat/ I know I've configured number resources in my internal networks that didn't belong to me, and no IP police came busting down my door. What matters isn't the IP number resources, it's the agreement among the com
Re: [arin-ppml] Deceased Companies?
Paul - I have no idea what "if I obtained a legacy IP block and tried to clean up the registration” even means? If you obtain a legacy block via the transfer market, it will already have been verified and cleaned up by the seller as part of the transfer process. The transfer cannot complete otherwise. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On 25 Jul 2022, at 4:02 PM, Paul E McNary via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: John you have repeatably told me I would risk revocation if I obtained a legacy IP block and tried to clean up the registration. You have now changed you mind and I would no longer have to worry if I obtained a legacy IP block from a friend? ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 25 Jul 2022, at 3:58 PM, Paul E McNary via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: I think we are talking about number resources here not the individual numbers. Predecessor entities (pre ARIN) made commitments for the "Number Resources" that were allocated. Paul – It might be helpful if you could provide that list of commitments, and the source of each? ARIN assumed those responsibilities and commitments and agreed not to alter them. ie. continue to route "all" number resources that had been previously assigned by Pre-ARIN entities. Wow. ARIN does not route your address blocks, and ARIN has no authority to command that those who do route (or don’t route) your address blocks do so. ARIN only administers the registry – ISPs decide what blocks to route based on their needs and business practices. ARIN keeps trying to stop honoring or threaten to stop honoring these agreed to commitments they made. Again, a list of those commitments your believe you were promised might be quite helpful to this discussion... I’m fairly aware of the commitments that ARIN made at inception – it certainly includes having an open and transparent process for the community to set number resource policy and then operating the registry according to that policy. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
question: Would they? When would they? Why would > they? Yes, RSD would handle accordingly - there is no reason not to, particularly given that the address block is presently utilized and there is no other party claiming they hold the rights. It is interesting - people alternately accuse ARIN of being hard to satisfy, and then express surprise when we go above and beyond to accommodate people attempting to clean up the registration records of blocks that they requested long ago and have been using since… >> Am I to presume you're seeking some other outcome for George? (i.e. given >> that you are >> asking whether ARIN can start rejecting his RSA fee payments?) > > Yes, you may so presume. I look forward to you proposing policy to that effect. The postulated case would be an Org recovery, as per NRPM 8.2. If you wish to add more exacting criteria to that section, describe the present problem as you see it, and the suggested outcome in a policy proposal. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
Paul - Nothing “unofficial” about any of this – ARIN operates the registry according to the Policies published on the ARIN website, including those in the Number Resource Policy Manual. We apply these policies uniformly to all requests and are periodically audited to insure consistency of policy application – see "Registration Services Audit Reports” – https://www.arin.net/about/corporate/rsd_audits/ Thanks, /John John Curran President and CEO American Registry for Internet Numbers On 25 Jul 2022, at 3:22 PM, Paul E McNary via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: John What I have found is that there is "Official" ARIN policy and policy created by the You and the Staff and you may or may not enforce it based on your wishes and desired outcome. You were just asked for policy example for clarification from Owen and you did a hard refusal. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 3:12 PM, William Herrin wrote: > > On Mon, Jul 25, 2022 at 11:18 AM Paul E McNary wrote: >> Then why the threat? > > Hi Paul, > > In my opinion? ARIN has a legal house of cards built on the premise > that there are no property rights in IP addresses. It's "true" until a > court says otherwise so they want to give the court as few reasons as > possible to say otherwise. Like any legal threat, the idea is to keep > the matter out of court be gaining compliance. A very amusing Interesting assertion – particular given ARIN’s track record of success in court. My advice remains to comply with ARIN policy, as ARIN has never been ordered to update the registry contrary to our policies. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 3:05 PM, William Herrin wrote: > >> You are describing nearly any legacy address block which was reclaimed and >> reissued >> by ARIN because it was determined to be abandoned (i.e. registered to an >> legal entity >> which no longer exists.) We don’t do this very often because of precisely >> the possibility >> discussed earlier on this list about parties attempting to resuscitate >> dissolved and/or >> bankrupt estates, but it does occur. >> >> I’ll pass on naming specific blocks, particularly as no one who has been >> issued such >> resources (e.g. via the waitlist) deserves undo attention as a result. > > Example or it didn't happen. You know this is among the first things > that would be demanded in legal discovery so you may as well lay it > out for folks. Bill - If you violate ARIN’s registry policies, your legacy address block will be subject to revocation, and ff ARIN then revokes your block, then you can entertain your legal theories as much as you wish. However, until such time, I shall not create disputes where none presently exist, nor contention without due cause for those who are enjoying their issued number resources. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 2:48 PM, William Herrin wrote: > > On Mon, Jul 25, 2022 at 11:35 AM John Curran wrote: >>> On 25 Jul 2022, at 2:09 PM, William Herrin wrote: >>> On Mon, Jul 25, 2022 at 8:02 AM Fernando Frediani >>> wrote: >>>> Question here John: if the resources are legacy and they were assigned >>>> before ARIN existence, these resources should ideally be reverted back >>>> to IANA which in turn should apply the Post Exhaustion Global Policy >>>> from May 6th 2021 and re-distribute these blocks to all RIRs ? >>> >>> John can correct me if I'm wrong but as far as I know, ARIN has NEVER >>> reclaimed legacy resources which were neither voluntarily returned nor >>> then operating under a specific registrant contract with ARIN (such as >>> the LRSA). >> >> You are incorrect. > > Example please of a reclaimed and reassigned (e.g. to IANA) legacy > block which was neither brought under an ARIN contract before > abandonment nor released by the registrant of record? Bill – You are describing nearly any legacy address block which was reclaimed and reissued by ARIN because it was determined to be abandoned (i.e. registered to an legal entity which no longer exists.) We don’t do this very often because of precisely the possibility discussed earlier on this list about parties attempting to resuscitate dissolved and/or bankrupt estates, but it does occur. I’ll pass on naming specific blocks, particularly as no one who has been issued such resources (e.g. via the waitlist) deserves undo attention as a result. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 2:09 PM, William Herrin wrote: > > On Mon, Jul 25, 2022 at 8:02 AM Fernando Frediani > wrote: >> Question here John: if the resources are legacy and they were assigned >> before ARIN existence, these resources should ideally be reverted back >> to IANA which in turn should apply the Post Exhaustion Global Policy >> from May 6th 2021 and re-distribute these blocks to all RIRs ? > > Hi Fernando, > > John can correct me if I'm wrong but as far as I know, ARIN has NEVER > reclaimed legacy resources which were neither voluntarily returned nor > then operating under a specific registrant contract with ARIN (such as > the LRSA). Bill - You are incorrect. ARIN has reclaimed legacy resources, as legacy number resource assignments are just a limited set of rights to entries in ARIN’s registry database and subject to the same policies as all other registrants. You seem to believe in some magic essence that precludes ARIN from administering its own registry database – good luck with that – you might do better with an actual contract. (I note that the vast majority of such cases involving revocation of legacy resources had resources that creatively hijacked in one form or another, and the “registrant” that had operational control disappears rather contest the revocation – thus leaving ARIN free to see if we can find the bona fide registrant or legal successor…) Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
Paul - Legacy resources holders receive basic registry services without contract or payment to ARIN; the associated address blocks are in the ARIN registry and remain subject to ARIN’s policies. Thanks, /John John Curran President and CEO American Registry for Internet Numbers On 25 Jul 2022, at 1:08 PM, Paul E McNary mailto:pmcn...@cameron.net>> wrote: Legacy Resources do not have fees to ARIN if not under LRSA, correct? "compliance with policy " is a double edged sword. You do have an "Inside The Beltway" use of the US English language :-) ________ From: "John Curran" mailto:jcur...@arin.net>> To: "pmcnary" mailto:pmcn...@cameron.net>> Cc: "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 11:46:31 AM Subject: Re: [arin-ppml] Deceased Companies? Paul - That’s quite strange, since we’d already had estates probated with number resources at that time. Rights to number resources are not “freely held property” but rather similar to any other contractual right - i.e. if you are running an operation that using IP address blocks and it passes to your heir, there’s not reason that the IP address blocks could not pass as part of the assignment of the contract. If you were somehow suggesting that the rights to the address blocks in the registry could pass absent the corresponding contractual obligations such as the payment of fees, compliance with policy, then indeed I probably said “not possible.” Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 25 Jul 2022, at 12:22 PM, Paul E McNary mailto:pmcn...@cameron.net>> wrote: It was you John Curran at WISPAMERICA when it was at Louisville I think. So Legacy Resources or any Resources remain with the Estate, That is excellent to know! At the time your argument was that Number Resources were not property that could be probated. Your view was that Number Resources were not property at all. They could be assigned but not possessed. You were very clear about it. From: "John Curran" mailto:jcur...@arin.net>> To: "Fernando Frediani" mailto:fhfredi...@gmail.com>> Cc: "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 11:07:21 AM Subject: Re: [arin-ppml] Deceased Companies? On 25 Jul 2022, at 11:48 AM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Thank you very much for the clarification John. It is good to know that there has been a policy in the past for that to happen and that BoT has understood that although ARIN could be successor of SRI/GSI/NSI-InterNIC it would not make sense in the current or even past context at that point in time these resources to be retained by ARIN. Your opinion on the matter is noted. I shall not opine on the view of the ARIN Board on hypotheticals but will observe that ARIN has been responsible the overwhelming majority of space returned the IANA IPv4 free pool. One point to highlight is that the communication mentions "blocks that have been voluntarily returned to ARIN" which could be understood as basically any legacy blocks had necessarily to be returned to ARIN and that IANA agrees on that or if a given legacy resource holder wishes to return it directly to IANA would it be forbidden and directed by IANA to do to ARIN ? Legacy resource holders in the ARIN registry must return their resources to ARIN. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
Ronald - I am unsure of ARIN’s legal ability to not accept payment from George, but I am not certain it is relevant in this case, as: - George was associated with the original request for the address block for TMBBATS - The ARIN payments have been made - TMBBATS has wound down (as opposed to be sold to some other party or creditor) - The address block in question has been utilized throughout So, while it is true that the resources are registered to an entity that no technically longer exists, they are being utilized by a party that has a credible claim to be the legal successor to the rights to the address block, and there is no other party that might be harmed by recognition of same. ARIN’s job is to administer the registry for productive use, and it would appear that is what is happening in this case. I suspect that the Registration Services Helpdesk would ask that George register TMBBATS as a sole proprietorship, provide an appropriate attestation of the events, and update the records accordingly. Am I to presume you’re seeking some other outcome for George? (i.e. given that you are asking whether ARIN can start rejecting his RSA fee payments…) Thanks, /John John Curran President and CEO American Registry for Internet Numbers > On 25 Jul 2022, at 12:32 PM, Ronald F. Guilmette > wrote: > > In message , > Chris Woodfield wrote: > >> I'd expect that in the case of an assignee subject to the >> RSA/LRSA, this would be a self-correcting issue - if the assignee or its >> successor does not pay their registration fee... > > I'm sorry, but you have misunderstood the thrust of my question, most > probably because I have failed to make it clear. Please allow me to > try again by way of a hypothetical. (DISCLAIMER: Any resemblance to any > person or legal entity, living or dead, within the following text is purely > coincidental.) > > Imagine the following scenaro: > > George Smiley is an avid fisherman residing in Lakeport, California. In > 2001 George decides to turn his avocation into a professional endeavor. > So George incorprates his new business, obtains a business bank account, > and opens his new fishing supplies shop in Lakeport under the rubric of > "The Master Baiter Bait & Tackle Shop, LLC". He is told by a friend > shortly thereafter that the best way to get his shop noticed by a lot of > fishermen is to set up his own web site, and that he could even make some > additional money on the side by setting aside one corner of his volumous > store and converting it into an Internet cafe for the locals of Lakeport. > So of course, George goes to ARIN and gets a membership for his business > (hereinafter "TMBBATS, LLC") and he also obtains from ARIN a /24 block. > > Hypothetically, let's just say that this all happens around, say, 2003, > give or take. > > In late 2008 the Great Recession hits and George's business drops off > dramatically. He is forced to close the Bait & Tackle shop and its > associated Internet Cafe. He does so, and also closes the company's > bank account. (Because why wouldn't he?) He is a lazy bugger however, > so rather than doing the correct, proper, and decent thing and sending > a notice to the State of California that he is closing his business, he > simply stops filing the annual reports that all active California > corporations are obliged, under law, to file every year. > > After a year or two, the State of California notices this and thus strikes > George's business from the rolls of active California corporations. > > But there is still that matter of TMBBATS, LLC's ARIN membership and its > associated ARIN-issued /24. > > Because George had put his home address in as the "official" mailing address > of TMBBATS, LLC, even after George has effectively dissolved his company > he continues to receive (by snail mail or email) annual invoices from ARIN, > Inc. He and a few of his his friends are still using the /24 to host a > handful of their personal web sites, so George responds to these annual > ARIN invoices by sending ARIN an appropriately sized check *from his own > personal bank account* every year, like clockwork. > > My question was/is: Is there anything within either the RSAs or within the > NRPM which either (a) obliges or alternatively (b) prohibits ARIN from > accepting an annual fee payment from a legal entity that is *different > from* the legal entity which was the original recipient of the relvant > ARIN membership (i.e. the one that entered into the RSA�contract with ARIN)? > > I am looking at the first sentence in Section 4 of the current edition of > the ARIN RSA and I see that it contains the following language, which is > arguabl
Re: [arin-ppml] Deceased Companies?
Paul - That’s quite strange, since we’d already had estates probated with number resources at that time. Rights to number resources are not “freely held property” but rather similar to any other contractual right - i.e. if you are running an operation that using IP address blocks and it passes to your heir, there’s not reason that the IP address blocks could not pass as part of the assignment of the contract. If you were somehow suggesting that the rights to the address blocks in the registry could pass absent the corresponding contractual obligations such as the payment of fees, compliance with policy, then indeed I probably said “not possible.” Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 25 Jul 2022, at 12:22 PM, Paul E McNary mailto:pmcn...@cameron.net>> wrote: It was you John Curran at WISPAMERICA when it was at Louisville I think. So Legacy Resources or any Resources remain with the Estate, That is excellent to know! At the time your argument was that Number Resources were not property that could be probated. Your view was that Number Resources were not property at all. They could be assigned but not possessed. You were very clear about it. From: "John Curran" mailto:jcur...@arin.net>> To: "Fernando Frediani" mailto:fhfredi...@gmail.com>> Cc: "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 25, 2022 11:07:21 AM Subject: Re: [arin-ppml] Deceased Companies? On 25 Jul 2022, at 11:48 AM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Thank you very much for the clarification John. It is good to know that there has been a policy in the past for that to happen and that BoT has understood that although ARIN could be successor of SRI/GSI/NSI-InterNIC it would not make sense in the current or even past context at that point in time these resources to be retained by ARIN. Your opinion on the matter is noted. I shall not opine on the view of the ARIN Board on hypotheticals but will observe that ARIN has been responsible the overwhelming majority of space returned the IANA IPv4 free pool. One point to highlight is that the communication mentions "blocks that have been voluntarily returned to ARIN" which could be understood as basically any legacy blocks had necessarily to be returned to ARIN and that IANA agrees on that or if a given legacy resource holder wishes to return it directly to IANA would it be forbidden and directed by IANA to do to ARIN ? Legacy resource holders in the ARIN registry must return their resources to ARIN. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 25 Jul 2022, at 11:48 AM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Thank you very much for the clarification John. It is good to know that there has been a policy in the past for that to happen and that BoT has understood that although ARIN could be successor of SRI/GSI/NSI-InterNIC it would not make sense in the current or even past context at that point in time these resources to be retained by ARIN. Your opinion on the matter is noted. I shall not opine on the view of the ARIN Board on hypotheticals but will observe that ARIN has been responsible the overwhelming majority of space returned the IANA IPv4 free pool. One point to highlight is that the communication mentions "blocks that have been voluntarily returned to ARIN" which could be understood as basically any legacy blocks had necessarily to be returned to ARIN and that IANA agrees on that or if a given legacy resource holder wishes to return it directly to IANA would it be forbidden and directed by IANA to do to ARIN ? Legacy resource holders in the ARIN registry must return their resources to ARIN. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
Paul - I am not certain which John you reference (myself or John Sweeting) but I do not believe that your statement to be correct, and expect that you are summarizing a somewhat more extensive conversation. Number resources can certainly be part of an estate and go through probate – this is particularly true when associated with an active business that was operated as a sole proprietorship. For number resources that were not identified as part of an estate at probate and have been dormant since, it is possible that ARIN will seek to reclaim them for the community if it is brought to our attention that they were issued to an organization that no longer exists due to passing of the proprietor. Thanks! /John John Curran President and CEO American Registry for Internet Numbers > On 25 Jul 2022, at 11:45 AM, Paul E McNary via ARIN-PPML > wrote: > > I was told by John in person that heirs/successors had no legal rights to > legacy resources. > This was also repeated by ARIN staff at the time. > They would be automatically recovered on death. > > - Original Message - > From: "Chris Woodfield" > To: "Ronald F. Guilmette" , "arin-ppml" > > Sent: Monday, July 25, 2022 10:41:48 AM > Subject: Re: [arin-ppml] Deceased Companies? > > I’d expect that in the case of an assignee subject to the RSA/LRSA, this > would be a self-correcting issue - if the assignee or its successor does not > pay their registration fee, the resources would eventually reclaimed by ARIN > and eventually allocated via the waiting list. Other resources, however, > could easily stagnate and require remediation work to either connect to the > legal heir of the defunct assignee organization; just like biological > persons, there should be some effort to locate potential heirs/successor > organizations before officially declaring the resource abandoned. To my > knowledge, no such process exists. > > -C > >> On Jul 25, 2022, at 8:34 AM, Ronald F. Guilmette >> wrote: >> >> Please allow me to ask a different but related question. >> >> As I understand it, all ARIN members are obligated, on an annual basis, >> to pay a fee to ARIN for their membership, and also some additional fees, >> again annually, based upon their assigned number resources, and more >> specifically, based upon the number thereof. >> >> If any of that is not correct, then I hope and trust that someone will >> gently correct me. >> >> Assuming that it is correct however, is there anything within either the >> RSAs or within the NRPM that obliges member entities to make these annual >> payments to ARIN themselves, directly? Or may some third party make some >> such payments on behalf of, say, some specific member entity? >> >> >> Regards, >> rfg >> >> >> ___ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact i...@arin.net if you experience any issues. > > ___ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. > ___ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
On 25 Jul 2022, at 11:02 AM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Em 25/07/2022 11:34, John Curran escreveu: I have seen administratively and voluntarily dissolved corporations come back to life, so ARIN must consider this. Exactly… It turns out that dissolved isn’t necessarily a permanent state, and in addition “dissolved” doesn’t mean that the rights necessarily and automatically revert to the ARIN community – there may be one or more parties that has potential claim to the resources, either via bankruptcy or provisions of the corporate wind down. Question here John: if the resources are legacy and they were assigned before ARIN existence, these resources should ideally be reverted back to IANA which in turn should apply the Post Exhaustion Global Policy from May 6th 2021 and re-distribute these blocks to all RIRs ? Incorrect - ARIN is the successor registry for these assignments made by SRI/GSI/NSI-InterNIC and so they are returned to ARIN. To the extent determined by ARIN policy and ARIN’s Board of Trustees, number resources that are revoked, returned, or reclaimed by ARIN may be returned to the IANA and then would qualify as "Any IPv4 space returned to the IANA by any means” as stated the referenced global policy. This has occurred in the past - https://www.arin.net/vault/announcements/2012/20120611.html (see extract below) Thanks! /John John Curran President and CEO American Registry for Internet Numbers ARIN Returns Some IPv4 Address Space to IANA Posted: Monday, 11 June 2012 Given the recent ICANN Board adoption of Global Policy Proposal - IPv4–2011, the ARIN Board of Trustees at its 6 June meeting directed ARIN staff to return to the IANA the IPv4 address blocks that have been voluntarily returned to ARIN in recent years. The total amount of space being returned to the IANA amounts to roughly a /8 equivalent and includes the large block of IPv4 addresses returned to ARIN by Interop in 2010. Below is the final list of address space that has been returned to the IANA and this will be reflected in ARIN's database within the next few hours. * 45.2.0.0/15 * 45.4.0.0/14 * 45.8.0.0/13 ... ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 10:30 AM, Paul E McNary via ARIN-PPML > wrote: > > "voluntarily dissolved corporations" > This term has caused me much grief with ARIN. > I being a sole proprietorship had many issues and 2 years proving who I was > to get resources. > Amd it is almost impossible to get legacy resources transferred by ARIN if > from sole proprietorship. > It looks like sole proprietorships are heavily discriminated against in ARIN > policy and procedures. > WHY? Paul - There’s no bias against sole proprietorships, but recognize that there’s often a lack of readily verifiable documentation (unlike a registered legal entity) and the same ease with which we accept representations of a purported genuine resource holder aids those who frequently attempt to hijack your number resources. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
Adam - Contact the Registration Services Helpdesk… we deal with situations like this fairly often and can often find a way to either get the registration updated (so that the holder can use or monetize the resources) or have them relinquished back to the registry. Thanks! /John John Curran President and CEO American Registry for Internet Numbers > On 25 Jul 2022, at 10:30 AM, Adam Thompson wrote: > > I don't think there is any such process today. I would like to see such a > process exist. > > While you're addressing non-legacy blocks, though, I have the same > issue/question with *legacy* blocks. > I've recently identified almost a dozen Class C blocks (yes, they're that old > :-D) where I'm 100% certain they are not in use, and 99.9% certain I'm the > only person left on the planet who's aware of their existence... but I do > not, or no longer, have any legal connection to the assignees, so I can't > relinquish the addresses to ARIN. Some of those assignees never had a legal > existence in the first place (e.g. individual high schools), others no longer > exist, others have moved or changed identity so establishing the succession > to ARIN's satisfaction would be a nightmare. > > What kind of a process does/would/could exist for reclaiming unused legacy > blocks like these? Or are they just frozen in time and (address) space > forever and we're all OK with that? > > -Adam > > Adam Thompson > Consultant, Infrastructure Services > MERLIN > 100 - 135 Innovation Drive > Winnipeg, MB R3T 6A8 > (204) 977-6824 or 1-800-430-6404 (MB only) > https://www.merlin.mb.ca > Chat with me on Teams: athomp...@merlin.mb.ca > >> -Original Message- >> From: ARIN-PPML On Behalf Of Ronald F. >> Guilmette >> Sent: July 25, 2022 8:10 AM >> To: arin-ppml@arin.net >> Subject: [arin-ppml] Deceased Companies? >> >> Can some helpful soul please point me to the section of the NPRM that lays >> out the ARIN policy/policies that relate to ARIN members / resources holders >> that were, once upon a time, legally constituted corporate entities, but >> that >> have ceased being validly registered corporate entities? >> >> I am most particularly interested to know whether ARIN is either permitted >> or obligated to reclaim any number resources that may have been assigned to >> such entities. >> >> NOTE: I am asking now *only* about NON-LEGACY memberships & resources. >> >> >> >> Regards, >> rfg >> ___ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact i...@arin.net if you experience any issues. > ___ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Deceased Companies?
> On 25 Jul 2022, at 10:15 AM, Mike Burns wrote: > ... > I have wondered myself. I have heard of a team inside ARIN working to > identify such blocks, if my memory serves. Yes, but “it’s complicated…" > I have seen administratively and voluntarily dissolved corporations come > back to life, so ARIN must consider this. Exactly… It turns out that dissolved isn’t necessarily a permanent state, and in addition “dissolved” doesn’t mean that the rights necessarily and automatically revert to the ARIN community – there may be one or more parties that has potential claim to the resources, either via bankruptcy or provisions of the corporate wind down. > The duration of dormancy allowed varies from jurisdiction to jurisdiction. > These jurisdictions normally see an inflow of back filing fees as part of > resuscitation. > They may not have much incentive to prevent these things. > Complicated for ARIN, the blocks are hijack bait and could be put to proper > use through re-issuance, but it could be a thorny and expensive legal issue > and exposure. > It would be nice to have some idea of the scope of the issue. Even in the > case of old sole proprietorships where the registrant dies, the fate of > addresses is unclear. Correct - we’re looking to see what can be done when cases are reported to us, but it is a fairly manual and labor intensive process. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Thanks! - and a couple of reminders... (was: Re: CEO that takes the time to answer all questions)
Fernando - Discussion of “facts that happen in other RIRs or general Internet Governance” topics is simply wonderful in concept, but it is not inevitable that such discussion is intermingled with consideration of specific policy ideas and proposals – for example, such general topics could be discussed on a more general purpose "arin-discuss” mailing list. In the meantime, the charter of the ARIN-PPML mailing list remains as-is, and please adhere to it in your postings Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 24 Jul 2022, at 3:26 PM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Hello This doesn't look nice, either the way it is written or the way it is understood by ARIN. Policy-related ideas and issues can mean a lot of things, including facts that happen in other RIRs or general Internet Governance area that can impact that was people discuss and agree on policies here. This is fundamental to make up peoples mind when putting their reasons for supporting or not a proposal. I can understand ARIN possible concerns in order to avoid turning this email list in a general discuss list that could end up putting away truly interested people, but in the other hand it is necessary to be flexible enough to not close abruptly any discussions that are raised here and that is not necessarily attached to a given proposal or draft and be able to separate the different type of discussions which we know is not an easy thing The text as it is looks fine for me, but if ARIN still chooses to not interpret in a different and more flexible way I would be happy to support whatever necessary changes to make it in such way. Thanks for the clarification around this topic Regards Fernando On 19/07/2022 15:30, John Curran wrote: On 19 Jul 2022, at 2:07 PM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Hi John Thanks for the response back to community. But let take easier this thing about discussions on ARIN PPML mailing list. I know some people may not like of find it strange discussions that are not necessarily and exactly around a given proposal but it is not necessary to be like that. Basically anything that has to do with ARIN PPML being a proposal or not it is fair to be discussed here, including how the CEO of ARIN interacts with its community and clarify all necessary information. That´s undoubtedly is of high importance and other topics that may affect in some way the discussions here and how community makes up their minds to support or not a proposal. … Fernando - That’s not quite correct, as the scope of the arin-ppml mailing list is quite clear, and postings must be more than simply tangentially related to ARIN policy. As provided per <https://www.arin.net/participate/community/mailing_lists/#public-policy-mailing-list> – Open to the general public. Provides a forum to raise and discuss policy-related ideas and issues surrounding existing and proposed ARIN policies. The PPML list is an intrinsic part of ARIN’s Policy Development Process<https://www.arin.net/participate/policy/pdp/>, which details how proposed policies are handled. Discussion on PPML can cover a variety of policy related topics, and ARIN encourages free discussion. ARIN announcements to the PPML about policy proposals or draft policies include the proposal number or draft policy number in the subject field. Please retain the policy number in the subject line when you make comments about specific proposals or draft policies<https://www.arin.net/participate/policy/drafts/>. Your post or reply should open with a statement of support or nonsupport for the topic to allow others to follow discussions of interest more easily and make your position clear. If you want a more open forum for discussion of overall issues related to ARIN (i.e. more than just topics that are “policy related ideas and issues”), I would suggest that you support that position in the open consultation I referenced previously. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Thanks! - and a couple of reminders... (was: Re: CEO that takes the time to answer all questions)
Noah – Yes, ARIN’s consultation and suggest process is open to the community at large and utilizes the arin-consuilt mailing list for solicitation of feedback on specific proposed operational changes to the organization – https://www.arin.net/participate/community/acsp/process/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 19 Jul 2022, at 2:40 PM, Noah mailto:n...@neo.co.tz>> wrote: Hi John On Tue, 19 Jul 2022, 20:57 John Curran, mailto:jcur...@arin.net>> wrote: 3) If you think that it might be nice to have a more open forum for community discussion of overall issues related to ARIN [such as this one] without seeing ongoing reminders from me about staying on the mailing list’s purpose, and/or if you are thinking that might be really bad idea to have a most open discussion list, I note that either way there is presently a consultation open on that very question that closes in just a few days and has had very little community input to date – https://www.arin.net/announcements/20220621-consultopen/ Is the consultation open to all internet community which includes we folks who are not from the ARIN region in terms of participating on the same? Noah ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Thanks! - and a couple of reminders... (was: Re: CEO that takes the time to answer all questions)
On 19 Jul 2022, at 2:07 PM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Hi John Thanks for the response back to community. But let take easier this thing about discussions on ARIN PPML mailing list. I know some people may not like of find it strange discussions that are not necessarily and exactly around a given proposal but it is not necessary to be like that. Basically anything that has to do with ARIN PPML being a proposal or not it is fair to be discussed here, including how the CEO of ARIN interacts with its community and clarify all necessary information. That´s undoubtedly is of high importance and other topics that may affect in some way the discussions here and how community makes up their minds to support or not a proposal. … Fernando - That’s not quite correct, as the scope of the arin-ppml mailing list is quite clear, and postings must be more than simply tangentially related to ARIN policy. As provided per <https://www.arin.net/participate/community/mailing_lists/#public-policy-mailing-list> – Open to the general public. Provides a forum to raise and discuss policy-related ideas and issues surrounding existing and proposed ARIN policies. The PPML list is an intrinsic part of ARIN’s Policy Development Process<https://www.arin.net/participate/policy/pdp/>, which details how proposed policies are handled. Discussion on PPML can cover a variety of policy related topics, and ARIN encourages free discussion. ARIN announcements to the PPML about policy proposals or draft policies include the proposal number or draft policy number in the subject field. Please retain the policy number in the subject line when you make comments about specific proposals or draft policies<https://www.arin.net/participate/policy/drafts/>. Your post or reply should open with a statement of support or nonsupport for the topic to allow others to follow discussions of interest more easily and make your position clear. If you want a more open forum for discussion of overall issues related to ARIN (i.e. more than just topics that are “policy related ideas and issues”), I would suggest that you support that position in the open consultation I referenced previously. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] Thanks! - and a couple of reminders... (was: Re: CEO that takes the time to answer all questions)
Folks - Let’s see if I can do three things at once here: 1) Your approval of my communication style is most appreciated – I work for all of you (collectively) and simply I find the job easier with frank and open communications. 2) As a gentle reminder, arin-ppml is the mailing list for discussion ARIN number resource policy matters, and so let’s try to get back to that topic soon… 3) If you think that it might be nice to have a more open forum for community discussion of overall issues related to ARIN [such as this one] without seeing ongoing reminders from me about staying on the mailing list’s purpose, and/or if you are thinking that might be really bad idea to have a most open discussion list, I note that either way there is presently a consultation open on that very question that closes in just a few days and has had very little community input to date – https://www.arin.net/announcements/20220621-consultopen/ Again, thanks for your kind words and support! /John John Curran President and CEO American Registry for Internet Numbers On 19 Jul 2022, at 1:28 PM, Owen DeLong via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: Yes… It’s been my experience that several RIR CEOs have done so and I think it is a model that the others should emulate. John Curran Paul Wilson Axel Pawlik Alan Barrett It’s also been my experience that the ARIN board, RIPE board, and the members of the APNIC EC are extremely accessible to the community and very open and transparent about the actions of their respective bodies. I don’t mention LACNIC only because I don’t have sufficient experience interacting with them to comment. The remaining board not mentioned here could learn a lot from the examples set by the three I did mention. Owen On Jul 18, 2022, at 23:51 , Noah mailto:n...@neo.co.tz>> wrote: On Tue, Jul 19, 2022 at 9:12 AM Hank Nussbacher via ARIN-PPML mailto:arin-ppml@arin.net>> wrote: On 18/07/2022 17:41, John Curran wrote: I have almost nothing to do with ARIN but I would just like to say kudos to John for taking the time to answer *every* single question and issue raised by anyone and everyone. Not many CEOs even answer 1-2 emails. I would also like to echo the same sentiment as Hank... it's refreshing to see how John engages with this ARIN community. Cheers Noah ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net<mailto:i...@arin.net> if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 18 Jul 2022, at 9:55 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... P.S. I'm not sure that I ever saw from you a crisp answer to the question "How many times has ARIN enforced policy against a member in cases that (a) did not involve the non-payment of fees and that also (b) did not involve criminal fraud?" Is that number zero? It’s non-zero - I noted that such policy enforcement can and does occur for reasons other than criminal fraud and non-payment (per the attached 7 July 2022 reply to you & arin-ppml) A specific number of occurrences was not provided. Thanks, /John John Curran President and CEO American Registry for Internet Numbers Begin forwarded message: From: John Curran mailto:jcur...@arin.net>> ... Yes, revocations can occur for violations of the ARIN’s number resource policy manual (NRPM)) for any resource in the ARIN registry) and/or violations of one’s registration services agreement, if applicable. (I would note in particular that NRPM section 12 "Resource Review” requires cooperation with any request from ARIN for reasonable related documentation, and failure to comply with policy can result in revocation. <https://www.arin.net/participate/policy/nrpm/#12-resource-review>) I hope this information is helpful to your number resource policy efforts, /John ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 18 Jul 2022, at 10:14 AM, Ronald F. Guilmette > wrote: > ... > Why does ARIN need to have a "necessary purpose" to publish the names of the > people who sign on the dotted line? Why isn't it sufficient that by > publishing > this info, ARIN is serving the Greater Good and the Community's Best > Interests? > > Where is it written in law that ARIN must have a "necessary purpose" and where > is that term defined, exactly? "ARIN obtains personal data only for specific lawful purposes and by consent of the individual.” and "Organizations should only provide Personal Data (of their staff, customers, or others) to ARIN with the consent of the affected individuals.” > Does the UK goverment have a "necessary purpose" in publishing the names and > addresses and nationalities of all of the beneficial owners of all UK > corporate entities? If so, then what is that "necessary purpose" exactly? > If not, then please explain why the UK can publish information that ARIN > cannot? (This ought to be interesting!) The United Kingdom is a sovereign entity. >> Therefore, if you wish more detail on a given legal entity that happens to >> hold number resources in the ARIN registry, you need to deal with the >> corporate register of the respective country. > > I believe that's what we call a "non sequitur", i.e. a conclusion that does > not follow from the premise. > > As far as I am aware, ARIN is incorpotated in the U.S. State of Virginia and > must thus conform its behavior to the laws as they exist in the State of > Virginia. You seem to be making the rather remarkable claim that ARIN's > behavior is dictated by the laws that exist in Nevis & St. Kitts. > > On what are you basing that very facinating conclusion? ARIN’s Data Privacy does not allow processing of personal data [including publication] outside of the specific lawful purposes for which it was collected. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
Paul - As noted, it was possible to refute Ronald’s claim (of ARIN’s purported failure to policy) for this particular request based entirely on public information – that is rarely the case, and why I said it’s generally not possible. FYI - If you wish to rename the ARIN’s "Internet Number Resource Fraud Reporting” process, please submit your suggestion here - https://www.arin.net/participate/community/acsp/process/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 18 Jul 2022, at 9:56 AM, Paul E McNary mailto:pmcn...@cameron.net>> wrote: John you just did discuss the resource holder publicly in question. You stated you reviewed the case in question. Go back and look at your own words. You shared that they had been properly vetted with policy in place at the time, did you not? That is a public statement, is it not? Your Inside the DC Beltway back and forth language is dis-heartening. I think ARIN needs to move to a politically more neutral location, perhaps Kansas City and get outside of the Beltway and it's use of the English language which id evidently different than the Midwest. The Federal Government did that with a major division in the Department of Agriculture to save money. So I think it would be best if ARIN relocated to better utilize member resources(money) it is given in trust. John you are a "master" waffler. I will not use a system with "fraud" in it's label to report non-fraud. The name of the system, I think, needs to change to use as you recommend. ____ From: "John Curran" mailto:jcur...@arin.net>> To: "Ronald F. Guilmette" mailto:r...@tristatelogic.com>> Cc: "arin-ppml" mailto:arin-ppml@arin.net>> Sent: Monday, July 18, 2022 8:44:01 AM Subject: Re: [arin-ppml] Reclamation of Number Resources On 18 Jul 2022, at 7:33 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... So when you say (paraphrasing) "It is unclear if ARIN could ever provide a public justification of the properness of the issuance..." of either a membership or a number resource... well... you've just proven that it *is* possible, at least in this one rather specific instance, yes? Maybe it could be possible in other instances also (?) It might be possible in other instances where the claim of inappropriate application of policy by ARIN staff is equally specious and can shown such entirely through public references. As I noted earlier, we rather frequently receive reports that allege improper issuance only to find out that that they stem from insufficient understanding of the applicable Internet number resource policy on the part of the submitter. Yes. And in all of those cases it should never be necessary for ARIN to give out anybody's confidential information, right? Because you can just do exactly what you have done in this case, i.e. helpfully explain to the party that raised the issue/question why they simply have, as you put it, an "insufficient understanding of the applicable Internet number resource policy". And wouldn't that be the most helpful, friendly, and polite thing to do in all such cases? We do sometimes can supply similar explanations to the submitter of an Internet number resource fraud report, but that’s rather uncommon since it is quite rare to receive claims that are blatantly faulty in the face of entirely public information. In any case, the disposition of each report is provided in the quarterly findings reports - https://www.arin.net/reference/tools/fraud_report/results/ I suppose that you are correct, John, that in this case the error was all mine in having failed to understand and appreciate that even as recently as 2016 the ARIN membership did not take seriously the possibility of interlopers from outside the region coming into the region to grab whatever was left of ARIN's already dwindling resources. And thus, for my mistake I will say "Mea cupla!", fall on my sword, and do whatever other groveling may be appropriate in this circumstance. ... But I am hoping that you will be so kind as to point me to the place where I may myself review the NRPM as it existed back in 2012. When I highlighted the the adoption of NRPM section 9 was in 2016, I did so via a link to the NRPM change log (which includes all of the versions of the Number Resource Policy Manual since inception) - https://www.arin.net/participate/policy/nrpm/changelog/#nrpm-change-log Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.ne
Re: [arin-ppml] Privacy of ARIN registry data (was: Re: Reclamation of Number Resources)
On 18 Jul 2022, at 9:04 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: In message <6d0e26dd-2b7d-49f3-9889-6b2d0cc41...@arin.net<mailto:6d0e26dd-2b7d-49f3-9889-6b2d0cc41...@arin.net>>, John Curran mailto:jcur...@arin.net>> wrote: If you wish the ARIN registry to obtain and/or publish "the names and full contact information of any and all officers, directors, shareholders, and/or legal representatives of any given member", you would need to propose a policy that clearly notes the necessary purpose for the collection and processing for this information, and have the ARIN community concur and adopt said policy. Yes. But how about a policy of ARIN just publishing the name & contact info of each natural person representative of each legal entity that is an ARIN member and who filed the membership application? You already have that information in your files, so there is no issue of "collecting" that because you already have it, agreed? Ah, no... there would be a very significant issue, as we did not collect the data for that purpose and thus have no consent to publish it as you suggest. We may be able to go out and individually obtain such consents (although I expect there may be just a few organizations who decline, and that would likely defeat your goals in publication. ) Alternatively, it might be possible for us publish that information as you suggest if the ARIN community developed a policy that required such publication which included a very clear and specific need for ARIN to so do in order to fulfill its mission. (I’m not sure that’s actually possible, as we have been fulfilling our mission successfully for decades without publishing the data as you propose.) In the end, we would probably need to make the requirement for publication of this information explicit in the RSA. Note that doing so for all existing parties would require both a Board recommendation for the change and then a member ratification vote – as changes to everyone’s existing RSA, other than as needed for conformance to prevailing law, have been put under member control as per Section 1 of the RSA. So, yes, just a few issues involved... Absent such a policy, what you seek would represent a fairly significant departure from what are becoming commonly accepted principles for personal data privacy and processing of personally identifiable information. Baloney! "Commonly accepted principles for personal data privacy and processing of personally identifiable information" ?? Where are you getting this from John? Europe? Just because THEY have chosen to shoot themselves in the foot with their newfound privacy fetish, that's no reason why we should. ARIN serves numerous jurisdictions with such personal data privacy principles now in place, including Canada and many US states, and ARIN has a Personal Data Privacy Policy which embeds similar concepts - https://www.arin.net/about/privacy/ Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 18 Jul 2022, at 7:33 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... So when you say (paraphrasing) "It is unclear if ARIN could ever provide a public justification of the properness of the issuance..." of either a membership or a number resource... well... you've just proven that it *is* possible, at least in this one rather specific instance, yes? Maybe it could be possible in other instances also (?) It might be possible in other instances where the claim of inappropriate application of policy by ARIN staff is equally specious and can shown such entirely through public references. As I noted earlier, we rather frequently receive reports that allege improper issuance only to find out that that they stem from insufficient understanding of the applicable Internet number resource policy on the part of the submitter. Yes. And in all of those cases it should never be necessary for ARIN to give out anybody's confidential information, right? Because you can just do exactly what you have done in this case, i.e. helpfully explain to the party that raised the issue/question why they simply have, as you put it, an "insufficient understanding of the applicable Internet number resource policy". And wouldn't that be the most helpful, friendly, and polite thing to do in all such cases? We do sometimes can supply similar explanations to the submitter of an Internet number resource fraud report, but that’s rather uncommon since it is quite rare to receive claims that are blatantly faulty in the face of entirely public information. In any case, the disposition of each report is provided in the quarterly findings reports - https://www.arin.net/reference/tools/fraud_report/results/ I suppose that you are correct, John, that in this case the error was all mine in having failed to understand and appreciate that even as recently as 2016 the ARIN membership did not take seriously the possibility of interlopers from outside the region coming into the region to grab whatever was left of ARIN's already dwindling resources. And thus, for my mistake I will say "Mea cupla!", fall on my sword, and do whatever other groveling may be appropriate in this circumstance. ... But I am hoping that you will be so kind as to point me to the place where I may myself review the NRPM as it existed back in 2012. When I highlighted the the adoption of NRPM section 9 was in 2016, I did so via a link to the NRPM change log (which includes all of the versions of the Number Resource Policy Manual since inception) - https://www.arin.net/participate/policy/nrpm/changelog/#nrpm-change-log Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 18 Jul 2022, at 8:42 AM, Ronald F. Guilmette > wrote: > > In message , > John Curran wrote: > >> ARIN requires that organizations are properly registered as a legal entity >> in order to sign n RSA and request resources. > > Yes, I think we all know that. > >> Organizations requesting number resources are subject to the laws in which >> they operate > > Yes, I think we all know that. > >> each of these jurisdictions has its own regulations that address how much >> information about registered legal entities is made public. > > You left out "...by the national governments of those jurisdictions." > > Believe me when I say that I am well and truly aware of the fact that > the national governments of Anguilla, Antigua & Barbuda, Bahamas, Barbados, > Bermuda, Cayman Islands, Nevis & St. Kitts, the British Virgin Islands, > and even some U.S. States decline to provide information about the officers, > directors, shareholders, and/or beneficial of corporate entities registered > in those jurisdictions. In fact it is my hope that everyone on this list > is well aware of that. > > But what has any of that got to do with ARIN? Ronald - You’re seeking more detailed information about the legal entities that hold the rights to number resources in the ARIN registry. Some of the information you seek may indeed be collected and processed at the time of entering a registration services agreement and/or making a resource request, but it is not collected for purposes of publication – nor is it clear that ARIN, under present policies, could ever assert a necessary purpose that would allow publication (beyond the points of contact that are provided by the organization specifically with the understanding that they are made public in the ARIN registry via Whois, etc.) Therefore, if you wish more detail on a given legal entity that happens to hold number resources in the ARIN registry, you need to deal with the corporate register of the respective country. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 18 Jul 2022, at 7:44 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: In message <779ca4f6-751c-436e-a6c4-ca21c8db7...@arin.net<mailto:779ca4f6-751c-436e-a6c4-ca21c8db7...@arin.net>>, John Curran mailto:jcur...@arin.net>> wrote: Hopefully this works out well and any type of information brought to any RIR in such manner gets investigated and in the worst case scenario resources get revoked as they should. No - parties that wish to bring information necessitating a review of a resource request should use the described reporting process, as ARIN will not act off allegations of this nature made on ARIN-ppml nor are such allegations conformant with the purpose of this mailing list. On that last point John, are you asserting that it is somehow non-germane to the ARIN public policy list to discuss here possible deviations, by ARIN, of its enforcement of policy? Ronald - If you wish to have investigation of a particular resource request for possible Internet number resource fraud or a “possible deviation of policy enforcement by ARIN”, please utilize the aforementioned Internet Number resource fraud reporting process – https://www.arin.net/reference/tools/fraud_report/ (ARIN will not publicly discuss the specific implementation of policy with regard to any party or their associated resource requests, so do not raise these on the arin-ppml mailing list.) Are you unilaterally defining the purpose of this mailing list to only include the _formulation_ of policy but never its associated enforcement? Not at all - If you wish to discuss a policy-related enforcement issue _in general_ (whether due to existing policy language or ARIN’s implementation of same), feel free to utilize the arin-ppml mailing list for that purpose. Note that ARIN reports back on implementation issues with policy both in the Policy Experience Reports provided at each ARIN meeting as well as quarterly summaries of fraud report findings - https://www.arin.net/reference/tools/fraud_report/results/, and these can be great starting points for raising implementation concerns. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] Privacy of ARIN registry data (was: Re: Reclamation of Number Resources)
> On 16 Jul 2022, at 7:31 AM, Ronald F. Guilmette > wrote: > ... > As I have stated at some length, I *do not* agree with that when it comes > to identifying the name, location and other contact details about the > business (and/or the natural person) that is the member, and when it comes > to identifying the names and full contact information of any and all > officers, directors, shareholders, and/or legal representatives of any > given member that are known to ARIN. All of that information for *all* > members should *already* be out on the table, and public, totally independent > of any cases of "fishy facts”. Ronald - To be clear, ARIN has the full organization name and its address publicly visible in the ARIN registry. We used to encourage organizations to use entries for their administrative and technical contact which consisted of actual (natural) people (including their name/address/email/phone) but no longer do so because it is unclear that there is specific and legitimate purpose for doing so. Organizations can continue to use natural people for their contacts if they choose (as opposed to organizational role accounts), but bear the burden of obtaining the consent of the affected individuals and taking on the responsible for the ongoing accurate maintenance of such data. If you wish the ARIN registry to obtain and/or publish “the names and full contact information of any and all officers, directors, shareholders, and/or legal representatives of any given member”, you would need to propose a policy that clearly notes the necessary purpose for the collection and processing for this information, and have the ARIN community concur and adopt said policy. Absent such a policy, what you seek would represent a fairly significant departure from what are becoming commonly accepted principles for personal data privacy and processing of personally identifiable information. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 16 Jul 2022, at 7:22 AM, Ronald F. Guilmette > wrote: > ... > The bottom line is that it should not take either an act of congress or > even a subpoena to find out just the names and the contact info for the > people who have submitted membership applications to any RIR, including > ARIN. But it does. ARIN requires that organizations are properly registered as a legal entity in order to sign an RSA and request resources. Organizations requesting number resources are subject to the laws in which they operate – each of these jurisdictions has its own regulations that address how much information about registered legal entities is made public. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
The community expects the community-developed number resource policy to be utilized in management of the registry and this is done uniformly and without exception. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 16 Jul 2022, at 2:48 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... As I have stated, it is my belief that both ARIN members and the Internet using public at large would be best served if ARIN would simply give a thumbs up / thumbs down at the end of any such review it performs. It can phrase these concluding pronouncements in the manner I have suggested, i.e. by simply saying that ARIN either will reclaim resources (and/or terminate a membership) or that it declines to do so at the present time. (It need not explain or elaborate in any way on any such decision.) Despite the failure to submit a report, a review was done in this case, and as I reported – "The resource request was reviewed and it was found to be issued correctly. “ Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 15 Jul 2022, at 10:12 AM, Fernando Frediani wrote: > > On 15/07/2022 11:04, John Curran wrote: >> >>> >>> Hopefully this works out well and any type of information brought to any >>> RIR in such manner gets investigated and in the worst case scenario >>> resources get revoked as they should. >>> >> No – parties that wish to bring information necessitating a review of a >> resource request should use the described reporting process, as ARIN will >> not act off allegations of this nature made on ARIN-ppml nor are such >> allegations conformant with the purpose of this mailing list. > Sure John. Whenever I have a case myself I would be glad to report via this > informed process. > > Just a quick clarification: in such situations does the investigated member > gets to know or have the right ti know who reported it or is it something > that doesn't really matter for the context and ARIN preserves the source of > information ? We exclude the report submitter information during our investigation and reporting to preserve anonymity of the submitter. (Note that, If appropriate, ARIN may refer fraud reports to the appropriate government and/or law enforcement agencies and cannot assure anonymity of such reports.) /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 15 Jul 2022, at 9:57 AM, Fernando Frediani mailto:fhfredi...@gmail.com>> wrote: Although I rarely agree with Owen views I have to say I do in this case. The situation seems simpler than it look like. It is healthy that investigations in such cases as conducted independent of too much formalities. I have already done similar thing in another situation in another RIR and they did investigate further and came to some conclusion about fraud. This doesn't mean a hunt for the applicant but the most important thing to prevail is if there was a fraud or a mistake or not at some point and if there was everybody is loosing, therefore it needs to be fixed. The resource request was reviewed and it was found to be issued correctly. Hopefully this works out well and any type of information brought to any RIR in such manner gets investigated and in the worst case scenario resources get revoked as they should. No – parties that wish to bring information necessitating a review of a resource request should use the described reporting process, as ARIN will not act off allegations of this nature made on ARIN-ppml nor are such allegations conformant with the purpose of this mailing list. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 15 Jul 2022, at 5:04 AM, Owen DeLong mailto:o...@delong.com>> wrote: That’s not what Ronald is describing here… Ronald is describing a situation where an organization likely submitted no documentation about the presence or absence of a sufficient tie to the region and ARIN staff likely erroneously missed this detail on their application. ... Owen - I’m not certain that your recasting of Ronald’s original request is correct, as he most certainly suggested more than ARIN staff missing a detail on the request – On the basis of all of the foregoing, and for the sake of the law abiding Internet user community which prefers not to see ARIN bending rules in order to support online criminal enterprises, ... How many other corporate entities have been accepted for membership by ARIN staff on the basis of mere shell company incorporations within the region where the deception could have been seen (or could now be seen) as readily apparent, … (i.e., suggesting that an “online criminal enterprise" obtained Internet number resources via “deception" …) Such an instance is NOT fraud by the definition above IMHO (and apparently in Ronald’s as well). As such, I think your continued use of the term fraud here is actually incorrect and that the fraud process is likely not the best mechanism for Ronald’s report (though it may be the closest process ARIN currently has). It’s actually the correct process for suggesting that the ARIN review an issuance to see if it was made in error – you might not like the name, but the “Internet Number Resource Fraud Reporting” process is indeed how someone suggests that false or deceptive information was submitted to ARIN (such as an allegation that some party represented having a substantial connection as required per policy where none actually existed.) This discussion has, however, strayed from that central point to also cover certain deficiencies in the disclosure level of the fraud reporting process which I believe should also be addressed, but should not be conflated with Ronald’s original information and concern. Perhaps expanding the fraud reporting process into a suspected policy violation reporting process could address this, or perhaps a separate process for reporting concerns over potential ARIN errors/mistakes/etc. would be best. I don’t have a dog in that particular fight at the moment, but the current mechanism certainly isn’t ideal for addressing the particular situation in question. Given Ronald’s initial assertions, the “Internet Number Resource Fraud Reporting” process serves that exact purpose; i.e., a review of the request to determine the veracity of information against the applicable Internet number resource policy. If you’d like to suggest a different name, feel free to utilize the ARIN suggestion process to offer another name – or even augment/refine via the policy process section 12 of the NRPM that formally covers Internet Number Resource Review to more fully explain and encompass this process you feel that’s more appropriate. Of course, you are correct that this misses the real meat of the issue – the current review process is opaque except in cases where the issuance was determined to be in error (in which case the problem is corrected and a brief summary to that effect is provided.) It certainly doesn’t provide a detailed public justification of the properness of the issuance per the ARIN’s staff implementation of applicable number resource policy against the supplied information from the requester, and it is unclear if such could ever be provided. As I noted earlier, we rather frequently receive reports that allege improper issuance only to find out that that they stem from insufficient understanding of the applicable Internet number resource policy on the part of the submitter. Such is the case with the particular request Ronald noted – despite not receiving any report, for avoidance of doubt we did complete an internal review the request & supporting information and indeed it was issued correctly per the applicable number resource policy at the time of the request. I understand that answer is unlikely to satisfy some without a public dissection of the entire process, but that cannot occur without ARIN violating the confidential nature of requests for Internet number resources. Please utilize the Internet Number Resource Fraud Reporting” process (or whatever future name it might have) to initiate a review of suspect number resource issuance; ARIN will not, in general, act off allegations of this nature made on ARIN-ppml nor are such allegations conformant with the purpose of this mailing list. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubs
Re: [arin-ppml] Reclamation of Number Resources
On 14 Jul 2022, at 6:28 PM, Paul E McNary mailto:pmcn...@cameron.net>> wrote: You keep using the word fraud. This is not an issue of fraud by my understanding but ARIN POLICY. Please correct your misuse of your language. PLEASE Paul - Within the context of the ARIN community and the ARIN-PPML mailing list, the term “fraud” refers to ARIN’s defined internet Number Resource Fraud process, as described here – <https://www.arin.net/reference/tools/fraud_report/> – and as such “fraud” is indeed the proper term in the context of this discuss. (Please take note of this usage to avoid confusion in the future.). Note also that (depending on the particular circumstances), there is often actual contractual fraud involved as well – i.e., fraudulent misrepresentations made by a party during entry into the RSA with ARIN in order to obtain or transfer number resources. We do not distinguish because it is a nearly a difference without a distinction when it comes to ARIN’s number resource review processes – the contractual fraud simply being additional element that may result in criminal prosecution after number resource revocation by ARIN. Thanks, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 14 Jul 2022, at 5:35 PM, William Herrin 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 ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 14 Jul 2022, at 9:15 AM, Ronald F. Guilmette > wrote: > ... > What evidence, if any, have you got to the contrary? Why are you attempting > to shift blame to this member when it seems altogether apparent that the > fault lies only and entirely with ARIN staff? Ronald - If you have a case where you believe that resources were issued incorrectly, please report it. If you do not believe that resources were issued incorrectly, then do not report it. I am not sure it could be any simpler. > ... > You're dodging the questions John. I have mostly asked a number of very > generalized questions which have nothing specifically to do with this > specific member or with this specific case, to wit: > > *) Has ARIN avoided enforcement of policy against some members out of fear, > warranted or otherwise, of litigation? That’s an easy one - No, ARIN does not avoid policy enforcement our of concern of litigation. Many in the community would likely find that question amusing, as it is fairly well-known that ARIN is both quite familiar with litigation and has a proven track record of success. > If not, then please specify how many members have had their memberships > revoked OTHER THAN in cases of non-payment of fees and/or cases of > outright, blatant, and legally actionable fraud (e.g. Micfo)? I do not believe that there are a significant number cases of resource revocation for reasons other than non-payment, dissolution, or Internet number resource fraud. (Offhand to me, it is unclear why ARIN would have a significant number of resources revoked for any reasons aside from the above…) > *) How many more memberships are currently sitting on ARIN's books that, > as in this case, obviously should never have been there, and what > effort, if any, will ARIN now expend to find them and to terminate > the memberships involved? None that I am aware of – please let us know if you are aware of any such cases. > *) In light of the facts of this case, what will ARIN now do to strengthen > the vetting process, going forward, for new memberships? We have no "facts of this case" because there is not report of any Internet number resource fraud occurring. You seem to simultaneous allege policy violations in the issuance but also decline to make a report so that we can investigate. > It probably doesn't hurt also that 99% of all ARIN members are entirely blaise > when it comes to the topic of policy enforcement generally. But I guess you > could just call me old-fashioned. I have this old school belief that if > an organization is going to go to all the trouble to write down a set of > policies, then it really ought to take them seriously. > > That quite clearly DID NOT HAPPEN in the case of 1337 Services LLC (SL-206). You assert such on this mailing list, but when asked to report the violation of policy you decline – that is your choice. Thanks! /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
On 14 Jul 2022, at 7:36 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: In message <9cde9492-a18e-4baf-a0f8-dd0fccda4...@arin.net<mailto:9cde9492-a18e-4baf-a0f8-dd0fccda4...@arin.net>>, John Curran mailto:jcur...@arin.net>> wrote: If you wish that we investigate this matter, please submit a report of the suspected Internet number resources fraud as per this process https:// www.arin.net/reference/tools/fraud_report/<http://www.arin.net/reference/tools/fraud_report/> Thank you John, but I must decline that generous invitation for the following three good and compelling reasons: 1) I cannot, in all honesty and good conscience, report something as "fraud" where the set of pertinent facts, as I have elaborated them, *do not* suggest that there has been any fraud, deceit, or misrepresentation of any kind, at least not on the part of the member organization in question. ... Ronald - If you are correct in your assertions, then the organization will have made a representation of significant connection to the ARIN region in order to be issued number resources (despite having no such connection) – that would indeed constitute a fraud in the request for Internet number resources. 2) I could perhaps just be mis-remembering now, but it is my recollection that the last time I inquired about the nature of any possible follow-up which ARIN might undertake upon its conclusion of any investigation of any case submitted via ARIN's fraud reporting form that neither the original reporter, not the ARIN membership, nor the ARIN community, nor the public at large would ever be informed of the results of any inquiry that had been trigged by a fraud report submitted to ARIN. ARIN issues quarterly summaries of the results of investigation into fraud reports – https://www.arin.net/reference/tools/fraud_report/results/ This reports are not detailed as they nearly always represent a matter which is legal in nature and pending final determination. 3) The case of 1337 Services LLC (SL-206), which I have gone to some lengths to carefully research and document, raises a host of other questions and concerns about ARIN's ability and willingness to enforce existing ratified policies. It is my feeling that you, John, as CEO, should openly address these concerns and questions, and not simply endeavor to bury them all behind the opaque wall of silence that would seem to be ARIN's formalized "fraud" reporting process. ARIN will not publicly discuss details of specific requests for number resources, but does welcome reports of possible fraud and investigates them fully. Best wishes, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
[arin-ppml] ARIN Mailing List AUP reminder (was: Re: Reclamation of Number Resources)
Ronald – In addition, I remind you that the ARIN-ppml mailing list operates under the ARIN Mailing List Acceptable Use Policy <https://www.arin.net/participate/community/mailing_lists/aup/> – a policy that specifically prohibits using the list for "making accusations of criminal conduct in the absence of an indictment or conviction.” Given the nature of your some of your stated concerns, use of the Internet number resources fraud reporting process may help in avoiding conflicts in this regard. Thanks! /John John Curran President and CEO American Registry for Internet Numbers On 12 Jul 2022, at 10:05 AM, John Curran mailto:jcur...@arin.net>> wrote: Ronald - If you wish that we investigate this matter, please submit a report of the suspected Internet number resources fraud as per this process –https://www.arin.net/reference/tools/fraud_report/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers On Jul 12, 2022, at 9:39 AM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: … I respectfully request that you, John, and other ARIN staff, as ncessary, review this case with an eye towards terminating this membership, if warranted, and with an eye towards reclamation of the associated number resources at the earliest possible date, in accordance with existing ARIN policy. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net<mailto:ARIN-PPML@arin.net>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
Ronald - If you wish that we investigate this matter, please submit a report of the suspected Internet number resources fraud as per this process –https://www.arin.net/reference/tools/fraud_report/ Thanks! /John John Curran President and CEO American Registry for Internet Numbers On Jul 12, 2022, at 9:39 AM, Ronald F. Guilmette wrote: … I respectfully request that you, John, and other ARIN staff, as ncessary, review this case with an eye towards terminating this membership, if warranted, and with an eye towards reclamation of the associated number resources at the earliest possible date, in accordance with existing ARIN policy. ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
Re: [arin-ppml] Reclamation of Number Resources
> On 8 Jul 2022, at 12:52 AM, Ronald F. Guilmette
> wrote:
>
> In message <7f1c6797-f050-4424-a26a-385b14a0e...@arin.net>,
> John Curran wrote:
>
>> *) Violation(s) of out-of-region usage policy.
>>
>>
>> Such has not to my knowledge (and quite unlikely to occur, as "ARIN
>> registered
>> resources may be used outside the ARIN service region."
>> <https://www.arin.net/participate/policy/nrpm/#9-out-of-region-use>
>
> Thank you John.
>
> I just want to be sure that I am clear on this point. The relevant section
> of the NRPM, which you linked to, states:
>
>"Out of region use of ARIN registered resources are valid justification
>for additional number resources, provided that the applicant has a real
>and substantial connection with the ARIN region which applicant must
>prove (as described below) ..."
>
>"A real and substantial connection shall be defined as carrying on
>business in the ARIN region in a meaningful manner."
>
> (A lengthy list of possible means of demonstrating exactly such a "substantial
> connection" to the region is then elaborated.)
>
> The above, together with your statement, leaves me with two questions:
>
>1) The NRPM Section 9 verbiage I have quoted above is explicit in placing
>a restriction upon ARIN, apparently prohibiting it from assigning
>"additional number resources" to applicants that lack "a real and
>substantial {and provable} connection with the ARIN region".
>
>Perhaps I am just reading too much into this, but the way in which
>this section of the NRPM is worded certainly appears to give license
>to ARIN to provide *initial* assignments/allocations of number
>resources to parties or entities that entirely lack any real,
>substantial, and/or provable connection with the ARIN region, and
>that the NRPM policy, as written, only prohibits ARIN from provding
>resources to entities or parties which have no substantial connection
>to the region AND that are coming back for "additional" resources,
>presumably after they have already been assigned some such by ARIN.
>
>Am I reading that right and is that your interpretation also?
ARIN does not issue resources to organizations absent a real and substantial
connection to the ARIN region.
>2) Am I to understand that in the entire history of ARIN, or at least
>in the entire history of the above-quoted in-region "substantial
>connection" requirement, there have actually been a grand total of
>zero instances in which any party or entity had their ARIN resources
>reclaimed on the basis that the party or entity in question was found
>to have no substantial connection to the region?
Parties lacking a substantial connection to our service region should not have
been issued resources by ARIN,
so it is quite unlikely that they would be revoked on that basis - any such
revocation would be because of the
fraudulent application that asserts "a real and substantial connection to the
ARIN region” despite reality.
> As should be apparent, this latter point/question may have some relevance to
> the ongoing controversies wthin the AFRINIC region.
It is unclear if the questions have any relevance at all to that matter, as the
community in the AFRINIC region is
best suited to determine the number resource policies appropriate in that
region.
Thanks,
/John
John Curran
President and CEO
American Registry for Internet Numbers
___
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Re: [arin-ppml] Reclamation of Number Resources
On 7 Jul 2022, at 5:22 PM, Ronald F. Guilmette mailto:r...@tristatelogic.com>> wrote: ... It seems safe to assume that there have historically been some instances in which ARIN memberships have been terminated, and any associated assigned number resources reclaimed, if and when a given member has simply failed to pay fess due to ARIN. Yes - This does occur with ARIN-region number resources, although we provide significant opportunity for parties to cure such situations – <https://www.arin.net/resources/fees/returns/> My questions however have to do with situations where policy violations other than the non-payment of fees are involved. Specifically, I would like to know if any of you can recall past instances where number resources have been reclaimed, by ARIN, for any of the following reasons: *) Usage of the assigned number resources was no longer consistant with the original justification submitted to ARIN. To my knowledge this has only occurred in the ARIN registry when the original request to ARIN was actually fraudulent in nature (as opposed to bona fide requests at the time but since overtaken by events.) *) Violation(s) of out-of-region usage policy. Such has not to my knowledge (and quite unlikely to occur, as "ARIN registered resources may be used outside the ARIN service region.”<https://www.arin.net/participate/policy/nrpm/#9-out-of-region-use> *) Any other policy violations. Yes, revocations can occur for violations of the ARIN’s number resource policy manual (NRPM)) for any resource in the ARIN registry) and/or violations of one’s registration services agreement, if applicable. (I would note in particular that NRPM section 12 "Resource Review” requires cooperation with any request from ARIN for reasonable related documentation, and failure to comply with policy can result in revocation. <https://www.arin.net/participate/policy/nrpm/#12-resource-review>) I hope this information is helpful to your number resource policy efforts, /John John Curran President and CEO American Registry for Internet Numbers ___ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
