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Re: [sig-policy] Forwarded reply from Gordon Bader

Jeff,

Its very difficult to hold senior management directly responsible for the
implementation of a companies' policy - unless it's something like murder. Holding senior management directly responsible for policies of routing dark
space addresses is not exactly a felony any place in the world. However,
holding the company responsible is possible, given the right environment. I do not know if you can levy fines, they refuse to pay, it goes to civil court
and they say, where is the authority? Especially, when you target individual
members of senior management, personally.

That is why, since the companies recognize that they need to go to an ISP
or an RIR for their address space, thus they implicitly recognize the ISP and
RIR's right to grant address space, that can be used in court. This, I believe
is the only way, so far, that I see this working. If in order to make an
impact, a permanent loss needs to be demonstrated, then so be it. But, everyone would need to re-route and not to or through the company. I still think that it would only need to be done once or twice at the most
and everyone would fall in to line. Nothing like expensive capital sitting there
idle and upset customers taking their business else where. That translates
into lost revenue, lost careers, and lost jobs. The targeted company
should sit up and take notice.

If this were to happen to, pick a company - any company, AOL for example,
their senior management who decided to let dark space routing would pay the
price with loss of jobs, stock options and the rest. Termination for cause.
Basically the same effect, different route.

Also, I would suspect that notification from an RIR like APNIC to
the 5 largest stockholders and the members of the Board of Directors along
with letters to senior management specifying the problem and detailing
what will occur if they do not comply, would have an effect. Especially
by indicating that they would be essentially forcibly removed from the
business.

If that were to not work, public notification to their end customers
that they stand to be cut off from the rest of the Internet due to the
actions of their ISP or carrier, should also have the desired effect,
especially if it is also published that the company officers and
Board of Directors failed to take action. I also think that it could
be easily be explained by saying - the company has essentially
stolen IP addresses (by officially recognizing and routing them)
for use by people sending out SPAM. That is a simple enough
explanation to the general public and they will understand that.
If enough customers desert the company and go elsewhere, the
company should start to comply with cleaning up their routing
tables.

Regards,
Gordon


Jeff Williams wrote:

Gordon and all,

GB wrote:


Jeff and all,

The primary intent of the policy proposal is not the reassignment of
address space. The intent is to
remove the address space from carriers that provide routing for dark
address space.

Agreed. However the "teeth" is such a policy are a bit weak unless the
penalty fits the infraction. Temporarily reassigning of the address space
has no permanent effect on the infraction. Hence a short term loss in such
revenue to that infraction is minimal and may be a write off on their
business operations expenses on in their taxes. In addition passing
on those costs due to their own errant activities will likely be passed
on to their existing customers, much along the practice of ATT of the
past and present, for example.


Not for a minute
do I expect that ATT or MCI or Tumbleweed ISP to permanently loose their
assigned address space
for eternity. I would expect that after a fixed number of warnings that
a loss would indeed occur and with
loss, some economic pain would come, while they clean up their routing
tables so as to regain their
IP space allotment.

Not good enough as I outlined in brief above. For instance our members
excluding myself and perhaps 15 others have been boycotting ATT wireless
as well as local telephone service for more than a year now at a estimated
cost to ATT for $8m/month with no change in their policy to date. So no,
what is needed is severe fines to the management of such ISP's to be levied
on a day to day basis until they can show clearly a change in both policy
AND practice.


I would think that after a few days to a few weeks
of no traffic - read no revenue,
that they could come back on line and be much more proactive about not
routing dark space .

Nice dream, but no cigar...


Do I
think for a minute that ATT would loose their allotment and never regain
it. No and their law department
would be working overtime. However, with a loss, I believe that the
rest of the carriers would understand
that their actions would subject their IP allocation to withdrawal
also. The loss of revenue should be a
large motivation for change.

If such a loss of revenue is directed properly and precisely as well as
stair stepped for multiple infractions to include fines on each and every
member of Sr. Management, than yes it would be a large motivation.
However what you seem to be suggesting is far too weak...


I think that a public indication that the carrier/ISP lost its IP
space and thus its customers loosing
their Internet access, would certainly put pressure on the carrier/ISP
to clean up its act and stay clean.
I think that the Internet end users, being buried in SPAM would
understand that their very own ISP
was a large part of the problem and thus being sent to the woodshed.

This, as you propose it is wishful thinking. No you have to hold the
Sr.Managment directly responsible and do so by removing some of
their personnel financial burden from them and make multiple infractions
in a stair step upwards to larger and larger fines on each and every
one of them to gain the proper result.


Thanks,
Gordon

Jeff Williams wrote:


Tim and all,

Thanks for the clarification regarding this policy. However it seems obvious
that reassigning address space under such conditions would cause even
greater confusion regarding routing table accuracy. Hence it would seem
more than obvious that such a policy is not only unwise, it is troublesome
and disruptive unnecessarily.

Tim Jones wrote:




Dear Gordon and others,

You may be interested to know that APNIC does have an internal procedure whereby "bogon" lists are periodically monitored.

When an instance of APNIC unallocated address space being announced is detected, a "cease and desist" order as you put it, is sent to the announcing ASN, and also upstreams providing transit.

As well as requesting that the announcements cease immediately, these notices point out that this address space may be allocated to a third party at any time with obvious consequences for routing.

This procedure is handled by APNIC hostmasters, who can be contacted at helpdesk@apnic.net if you have any queries regarding this procedure.

Regards,

Tim.
--
____________________________________________________________________

Tim Jones Internet Resource Analyst <tim@apnic.net>
Asia Pacific Network Information Centre phone: +61 7 3858 3100
http://www.apnic.net fax: +61 7 3858 3199
Helpdesk phone: +61 7 3858 3188
Helpdesk Requests <helpdesk@apnic.net>

Please send Internet Resource Requests to <hostmaster@apnic.net>
_____________________________________________________________________
APNIC 18
Nadi, Fiji, 31 August-3 September 2004
http://www.apnic.net/meetings/18
------------------------------------------------------------------------

On Tue, 17 Aug 2004, GB wrote:




Hi Jeff,

Thank you very much for publishing the additional information. The
3 week period I referred to was just that one example that I had at hand
and did not want to cite anything longer because I did not have a
concrete example, just in case I was asked to provide additional
documentation. I also wanted to give the carriers the "benefit of
doubt" that they try to do a reasonable job at table maintenance.

In all honesty, I submitted the proposal to generate some thought
within the community on the problem and possible solutions. I do
realize that the various local legalities (local to the ISPs and various
carriers) as well as the previously cited international and trade
concerns create a very difficult landscape for such a proposal as this
to have any traction at all, especially with the drastic economic impact
that it carries. Coupling the various legalities, trade, economic
realities together, you wind up with a nearly insurmountable problem,
especially for a proposal that is rather simple and drastic in nature.

Given all of this, I ask the community, how else other than
sanctions that carry drastic economic consequences will such large
carriers (as well as smaller ISPs) essentially be forced to police
themselves? Has the servicing of dark space become a "cost of doing
business", and if so, what happens when it's growth creates a situation
that cannot be ignored? Does the community just legitimize the practice
and go forward? SPAM traffic now consumes well over 60% of email
traffic. Will we have a "controlled" area of IP space that co-exists at
some level with "uncontrolled" space - an extension of what we have
now? What happens when a new allocation is made that takes away
someone's use of dark space that they have been "using" for a
substantial period of time. Will they claim legal ownership under
something similar to real estate's "Adverse Possession"?

I would also like to ask something that I touched on before. Has
APNIC considered a test in that they would officially request that XYZ
(i.e., ATT, MSN, MCI, AOL, etc.) to return it's property (the
unallocated IP address space). Essentially, by routing a dark space
address, the service in question, is denying APNIC the control of it's
property that it needs back under it's control for authorized legal
allocation. A cease and desist order for lack of a better description.
It might be an interesting attempt. I would think that say ATT for
example, would have a difficult time denying APNIC's request to return
(stop routing a dark space address), when its own IP address allocation
has been derived from an RIR. What recourse would APNIC have if such a
request were either ignored or refused outright?

With regards,
Gordon


Regards,

--
Jeffrey A. Williams
Spokesman for INEGroup LLA. - (Over 134k members/stakeholders strong!)
"Be precise in the use of words and expect precision from others" -
Pierre Abelard

"If the probability be called P; the injury, L; and the burden, B;
liability depends upon whether B is less than L multiplied by
P: i.e., whether B is less than PL."
United States v. Carroll Towing (159 F.2d 169 [2d Cir. 1947]
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