Hello John, On Feb 17, 2014, at 5:30 PM you wrote:
"As noted earlier, RIPE 605 covers quite a bit of ground; could you be more specific about what specific policy changes you are seeking?" I agree that RIPE 605 covers a lot of ground, and there are opportunities to improve it. From my perspective, the core desirable policy points are as follows: 1. Formal preservation and recognition of the pre-existing rights of legacy resource holders, including the right to be left alone by ARIN without risk that legacy resource holders' registration records will be altered or removed except when they request updates or changes. 2. Codification of ARIN's commitment to maintain the existing registry records for legacy resources without regard to whether the holder of the legacy resource enters into a formal contractual relationship with ARIN for those legal resources. 3. Allowing legacy holders to obtain certain registry services as members or paying non-members under a new class of contracts that offer differentiated rights, responsibilities and registry services based on the nature of the formal relationship selected (e.g., member or non-member registry contract). 4. Offering entities that signed an LRSA or obtained legacy resources under RSA before the new policy is enacted an opportunity for a fresh look, giving them an equal opportunity to benefit from the flexibility of the new policy. In addition, there are several items worth considering as the policy proposal is reviewed and revised for the ARIN community. The following is my initial list: 1. For legacy resources that have "no relationship" with the RIR, the policy states that the RIR "may update the related entries in the [RIR] database from time to time to correspond to the current actual situation." I believe the policy should include some guiding criteria for when these updates may be made. 2. The policy sets some minimum contractual requirements, but it does not provide any guidance on the form of the contracts or any limitations on their scope. If the contracts are too onerous or one-sided, many legacy holders will continue to opt for the "no-relationship" status. To avoid this outcome, the policy should be crafted to ensure that the contracts are minimally intrusive and reasonably balanced (as if an objectively reasonable legacy holder and ARIN actually negotiated the terms and conditions at arm's length). 3. The 6 classes of legacy holder relationships could be streamlined considerably. 4. Transfer polices are not expressly covered. However, I believe the community should (again) reconsider whether needs justification is an appropriate pre-condition for ARIN to record in its registry database otherwise lawful conveyances / transfers between private parties (particularly after ARIN reaches its final phase of exhaustion). -Marc Marc Lindsey Levine, Blaszak, Block & Boothby, LLP 2001 L Street, NW Suite 900 Washington, DC 20036 Office: (202) 857-2564 Mobile: (202) 491-3230 Email: [email protected]<mailto:[email protected]> Website: www.lb3law.com<http://www.lb3law.com>
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