FYI: from nanog list. If this comes true, we gonna have a big mess. It's
worth reading.

F.

-------- Original Message --------
Subject: Can a Customer take their IP's with them? (Court says yes!)
Date: Mon, 28 Jun 2004 23:24:27 -0400 (Eastern Standard Time)
From: Alex Rubenstein <[EMAIL PROTECTED]>
To: [EMAIL PROTECTED]


Alex Rubenstein wrote:
>
> Please read -- this is lengthy, and important to the industry as a
> whole. We ask for, and solicit, comments, letters of support, etc.,
> for our position. We are looking for people to take a position on
> this, and come forward, perhaps even to provide an affidavit or
> certification. Something along the lines of a 'friend of the court'
> brief, or even comments as to why we are wrong.
>
> Read on.
>
> There has been a Temporary Restraining Order (TRO) issued by state
> court that customers may take non-portable IP space with them when
> they leave their provider. Important to realize: THIS TEMPORARY
> RESTRAINING ORDER HAS BEEN GRANTED, AND IS CURRENTLY IN EFFECT. THIS
> IS NOT SOMETHING THAT COULD HAPPEN, THIS IS SOMETHING THAT HAS
> HAPPENED. THERE IS AN ABILITY TO DISSOLVE IT, AND THAT IS WHAT WE ARE
> TRYING TO DO.
>
> This is a matter is of great importance to the entire Internet
> community. This type of precedent is very dangerous. If this ruling
> is upheld it has the potential to disrupt routing throughout the
> Internet, and change practices of business for any Internet Service
> Provider.
>
> In the TRO, the specific language that is enforced is as follows:
>
> "NAC shall permit CUSTOMER to continue utilization through any
> carrier or carriers of CUSTOMER's choice of any IP addresses that
> were utilized by, through or on behalf of CUSTOMER under the April
> 2003 Agreement during the term thereof (the "Prior CUSTOMER
> Addresses") and shall not interfere in any way with the use of the
> Prior CUSTOMER Addresses, including, but not limited to:
>
> (i) by reassignment of IP address space to any customer; aggregation
> and/or BGP announcement modifications,
>
> (ii) by directly or indirectly causing the occurrence of superseding
> or conflicting BGP Global Routing Table entries; filters and/or
> access lists, and/or
>
> (iii) by directly or indirectly causing reduced prioritization or
> access to and/or from the Prior CUSTOMER Addresses, (c) provide
> CUSTOMER with a Letter of Authorization (LOA) within seven (7) days
> of CUSTOMER's written request for same to the email address/ticket
> system ([EMAIL PROTECTED]), and (d) permit announcement of the Prior
> CUSTOMER Addresses to any carrier, IP transit or IP peering network."
>
>
> We believe this order to be in direct violation of ARIN policy and
> the standard contract that is signed by every entity that is given an
>  allocation of IP space. The ARIN contract strictly states that the
> IP space is NOT property of the ISP and can not be sold or
> transferred. The IP blocks in question in this case are very clearly
> defined as non-portable space by ARIN.
>
> Section 9 of ARIN's standard Service Agreement clearly states:
>
> "9. NO PROPERTY RIGHTS. Applicant acknowledges and agrees that the
> numbering resources are not property (real, personal or intellectual)
> and that Applicant shall not acquire any property rights in or to any
>  numbering resources by virtue of this Agreement or otherwise.
> Applicant further agrees that it will not attempt, directly or
> indirectly, to obtain or assert any trademark, service mark,
> copyright or any other form of property rights in any numbering
> resources in the United States or any other country."
>
> [Full ARIN agreement http://www.arin.net/library/agreements/rsa.pdf]
>
> Further, it is important to realize that this CUSTOMER has already
> gotten allocations from ARIN over 15 months ago, and has chosen not
> to renumber out of NAC IP space. They have asserted that ARIN did not
> supply them with IP space fast enough to allow them to renumber.
> Since they have gotten allocations from ARIN, we are confident they
> have signed ARIN's RSA as well, and are aware of the above point (9).
>
>
> If this ruling stands and a new precedent is set, any customer of any
>  carrier would be allowed to take their IP space with them when they
> leave just because it is not convenient for them to renumber. That
> could be a single static IP address for a dial-up customer or many
> thousands of addresses for a web hosting company. This could mean
> that if you want to revoke the address space of a spammer customer,
> that the court could allow the customer to simply take the space with
> them and deny you as the carrier (and ARIN) their rights to control
> the space as you (and ARIN) see fit.
>
> REMEMBER, THE INTERNET USED TO BE BASED UPON PORTABLE IP SPACE, AND
> IS NO LONGER FOR SEVERAL TECHNICAL REASONS.
>
> It is important to understand that this is not a situation where a
> customer is being forced to leave on short notice. NAC has not
> revoked the IP space of the customer. This is a situation where a
> customer is exercising their option not to renew their services and
> is leaving voluntarily. In addition the customer in question was
> granted their own IP space OVER A YEAR AGO and simply chose not to
> renumber their entire network. The key issue is that they want to
> take the space with them AFTER they leave NAC and are NO LONGER A
> CUSTOMER.
>
> Why this TRO is bad for the Internet:
>
> 1. It undermines ARIN's entire contract and authority to assign IP
> space.
>
> 2. It means that once IP addresses have been assigned / SWIP'ed to a
> Customer that the Customer may now have the right to continued use of
>  those addresses even if the customer leaves the service of the
> Provider. In other words the right of the Provider to maintain
> control and use of the address space assigned to his network, is to
> now be subject to the Customer going to a State Court and getting an
> Order to take such space with them.  Instead of the Addresses being
> allocated by delegated authority of the Department of Commerce and
> ARIN they become useable by anyone who convinces a Judge that they
> have a need for the addresses.
>
> It appears the Customer can keep the addresses for as long as it
> pleases the State Court and as long as the Customer can judicially
> hijack the space.
>
> The tragic part of this is that the Court which issues the Order does
> not even have to hear expert testimony.  So the Court can issue such
> Order without fully understanding the Internet Technology that is
> affected or the havoc it could cause in National and International
> Communications.
>
> 3. Significant potential for routing havoc as pieces of non-portable
> blocks of space are no longer controlled by the entity that has the
> assignment from ARIN, but by the end user customer for as long as
> that customer wants to use them. If the customer was causing a
> routing problem by improper routing confirmation the carrier would
> lose their authority to revoke or limit the use of the IP space to
> protect the stability of the carrier's network. In other words,
> court-compelled LOAs are a 'bad thing.'
>
> 4. Because the IP space is still assigned to the carrier, the carrier
>  would potentially be responsible to continue to respond to all SPAM
> and hacking complaints, DMCA violations, and all other forms of
> abuse. All of this abuse responsibility and liability would continue
> with no recourse to revoke or limit IP space of that customer and no
> ability to receive financial compensation for that task. This is not
> a theoretical problem, in the case of this customer we have received
> numerous abuse complaints throughout their history as a customer.
> While they have generally resolved these issues, it still is a real
> cost for us to handle. This is something that has the potential to
> create a massive burden for the carrier.
>
> 5. It would fundamentally change the long standing policy that the
> carrier that has the IP space assigned to them has the right to
> assign and revoke the IP space as it sees fit, and that the customer
> has no rights to the IP space other then the rights that the carrier
> gives them (through a delegation from ARIN).
>
> 6. If the customer is being DDOSed, or attacked (perhaps they may
> even instigate it purposely), and then stops announcing the more
> specific routes, the attack when then flow to us, the innocent
> bystander. Essentially, the customer could cause a DDOS for which I
> will then be billed for. This type of thing has been known to happen
> in the past (but not with this CUSTOMER).
>
> As you can see, this TRO has widespread effects, and is something
> that everyone in the industry could be affected by. If this precedent
> is set, you will soon have everyone acting as if IP's are property,
> and something that they are entitled to. I ask for input from
> everyone in the community on this. We don't think we're crazy, but
> want to make sure.

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