[address-policy-wg] 2015-05 Discussion Period extended until 13 May 2016 (Last /8 Allocation Criteria Revision)

> On 19 Apr 2016, at 23:11, Hans Petter Holen <hph at oslo.net> wrote:
> 
> On 14.04.2016 18.13, Jim Reid wrote:
>>> I know companies who've done this.  It isn't sensible.
>> True. But the NCC has ways to deal with those sorts of bad actors. Besides, the checks on a new LIR raise a reasonably high barrier for those who try to game the system in this way.
>> 
> No.
> I work for a multi-national corporation. We have multiple datacentres in multiple countries and these are organized as separate legal entities and have separate LIRs. This has been the practice of large multi-national LIRs for the last 20 years.
> 
> I do not see how that makes us a bad actor gaming the system.

I do not see that either Hans Petter. Or how anyone might consider that sort of behaviour to be a bad actor gaming the system.

As I’m sure you know, when an application for a new LIR is made, paperwork -- certificates of incorporation, tax registration numbers, contact details and so on -- has to be supplied to the NCC. This information gets checked. Those checks by the NCC are (or should be) strong enough to weed out membership applications by bad actors. Which presumably would not include the sort of good faith activity you described above.

Bad actors may well try to become an LIR to get address space “for free” from the NCC. But they'll first have to set up a legal entity, register it with the national tax authorities and chamber of commerce, pay a lawyer or accountant, etc, etc. The cost of all that effort plus the NCC fees is very likely to be similar to the value of their exactly one /22 on the secondary market. IMO these factors do raise barriers which should make it harder for an impostor to game the system without unduly inconveniencing genuine applicants. That’s what I was saying earlier.

Now there are ways to game address allocation. [There always have and probably always will.] You even mentioned some. It’s dpoubtful these sorts of activities would go unnoticed. And at the very least questions would (or should) be asked to establish if these actions were carried out in good faith or were something more suspicious than that.

Note too that I was not saying or implying that everyone who sets up an LIR to get a /22 -- or LIRs to get >1 /22 -- is a bad actor. Some wannabe LIRs might be up to no good. That’s just a fact of life: there’s always someone somewhere trying to break or bend the rules. But I trust the NCC’s checks are robust enough to identify these impostors and deal with them.

Further discussion about that should probably take place at the (A)GM and not on this list.