Re: [members-discuss] [ncc-services-wg] Update of RIPE NCC Procedural Document
Dear Maria, Thank you for the announcement. I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
I would not call this 'wording changes': $ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership? Thank you. -- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
Dear Sergey, Please allow me to explain why the change in Section 1.2.2.g was described as bringing alignment with the wording used in the RIPE NCC Standard Service Agreement. Article 9.4 of the RIPE NCC Standard Service Agreement (SSA) states the following: "The RIPE NCC shall be entitled to terminate the RIPE NCC Standard Service Agreement with immediate effect in accordance with the procedure set forth in the RIPE NCC document 'Closure of LIR and Deregistration of Internet Number Resources' ... h. if the Member provides the RIPE NCC with falsified or misleading data or provides the RIPE NCC repeatedly with incorrect data" According to this article, it is not a requirement that provision of falsified or misleading data by a member has to occur in a repeated manner for the RIPE NCC to be entitled to terminate their SSA. Also, it is one of the member's contractual responsibilities to provide the RIPE NCC with complete, up-to-date and accurate information that is necessary for the provision of the RIPE NCC services (Article 6.2). When applying the RIPE NCC procedures and before deciding to terminate a member's SSA in accordance with Article 9, the RIPE NCC makes sure that all conditions are met and there is enough evidence to support making this decision. Kind regards, Maria Stafyla Legal Counsel RIPE NCC On 03/04/2019 12:58, Sergey Myasoedov wrote:
Dear Maria,
Thank you for the announcement.
I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c). I would not call this 'wording changes':
$ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.). So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership?
Thank you.
-- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
Hello Maria, all,
On Apr 3, 2019, at 17:29, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Sergey,
Please allow me to explain why the change in Section 1.2.2.g was described as bringing alignment with the wording used in the RIPE NCC Standard Service Agreement.
Article 9.4 of the RIPE NCC Standard Service Agreement (SSA) states the following:
"The RIPE NCC shall be entitled to terminate the RIPE NCC Standard Service Agreement with immediate effect in accordance with the procedure set forth in the RIPE NCC document 'Closure of LIR and Deregistration of Internet Number Resources'
...
h. if the Member provides the RIPE NCC with falsified or misleading data or provides the RIPE NCC repeatedly with incorrect data"
According to this article, it is not a requirement that provision of falsified or misleading data by a member has to occur in a repeated manner for the RIPE NCC to be entitled to terminate their SSA. Also, it is one of the member's contractual responsibilities to provide the RIPE NCC with complete, up-to-date and accurate information that is necessary for the provision of the RIPE NCC services (Article 6.2).
Do you have exact criteria that define difference between falsified and incorrect data? Are these criteria written anywhere in RIPE NCC documents?
When applying the RIPE NCC procedures and before deciding to terminate a member's SSA in accordance with Article 9, the RIPE NCC makes sure that all conditions are met and there is enough evidence to support making this decision.
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
On 03/04/2019 12:58, Sergey Myasoedov wrote:
Dear Maria,
Thank you for the announcement.
I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c). I would not call this 'wording changes':
$ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.). So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership?
Thank you.
-- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
_______________________________________________ members-discuss mailing list members-discuss@ripe.net https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members-discuss/tasic%40hostmaster.ua
-- Best regards Taras Heichenko tasic@hostmaster.ua
Hi Taras, all We do not list in any of our procedural documents the exact criteria for differentiating between falsified and incorrect information. However, we do provide examples in Section 1.2.2.g of the closure document: "... The Member is in breach of good faith in the following cases: Falsified/incorrect information The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details)." Based on these, registration papers or identification documents that have been falsified would constitute falsified information whereas providing incorrect or inaccurate contact details would constitute incorrect information. Please note that the above violation of the SSA differs from maintaining incorrect registration data in the RIPE Database. The latter is a violation of the RIPE Policies and it would give the right to the RIPE NCC to terminate the member's SSA with a three-month period effect. During this period and in accordance with Section 1.2.1.1.c of the closure document, the RIPE NCC will send emails and reminders to the member asking them to rectify the violation. If the member continues to not comply after 90 days from the first email, the RIPE NCC will terminate their SSA. All in all, depending on the reason that leads to the termination of a member's SSA and its severity, termination will take place with either three-month or immediate effect and for this the RIPE NCC will follow the relevant procedure as documented in the closure document, available at: https://www.ripe.net/publications/docs/ripe-716 Lastly, by "Dutch authority orders" we mean a Dutch Court order served by a Dutch LEA as well as a binding order from law enforcement or regulatory authorities that are operating as required under Dutch criminal and administrative law (e.g. Public Prosecution Department, the Police, the Fiscal Intelligence and Investigation Service). For more information on how the RIPE NCC would react to a request or order for action you should refer to the RIPE NCC procedural document "Handling Requests for Information, Orders and Investigations from Law Enforcement Agencies": https://www.ripe.net/publications/docs/ripe-675 Kind regards, Maria Stafyla Legal Counsel RIPE NCC On 03/04/2019 18:46, Taras Heichenko wrote:
Hello Maria, all,
On Apr 3, 2019, at 17:29, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Sergey,
Please allow me to explain why the change in Section 1.2.2.g was described as bringing alignment with the wording used in the RIPE NCC Standard Service Agreement.
Article 9.4 of the RIPE NCC Standard Service Agreement (SSA) states the following:
"The RIPE NCC shall be entitled to terminate the RIPE NCC Standard Service Agreement with immediate effect in accordance with the procedure set forth in the RIPE NCC document 'Closure of LIR and Deregistration of Internet Number Resources'
...
h. if the Member provides the RIPE NCC with falsified or misleading data or provides the RIPE NCC repeatedly with incorrect data"
According to this article, it is not a requirement that provision of falsified or misleading data by a member has to occur in a repeated manner for the RIPE NCC to be entitled to terminate their SSA. Also, it is one of the member's contractual responsibilities to provide the RIPE NCC with complete, up-to-date and accurate information that is necessary for the provision of the RIPE NCC services (Article 6.2). Do you have exact criteria that define difference between falsified and incorrect data? Are these criteria written anywhere in RIPE NCC documents?
When applying the RIPE NCC procedures and before deciding to terminate a member's SSA in accordance with Article 9, the RIPE NCC makes sure that all conditions are met and there is enough evidence to support making this decision.
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
On 03/04/2019 12:58, Sergey Myasoedov wrote:
Dear Maria,
Thank you for the announcement.
I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c). I would not call this 'wording changes':
$ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.). So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership?
Thank you.
-- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
members-discuss mailing list members-discuss@ripe.net https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members-discuss/tasic%40hostmaster.ua -- Best regards
Taras Heichenko tasic@hostmaster.ua
Sergey , thanks for heads-up! There are tons of incorrect data in the RIPE DB, tons of allocated but unassigned (and used) space. And i suspect that many of these cases are with the old LIRs and especially big companies. So if the rules are the same for everyone should we shoot couple of big telecom companies LIRs? Is incorrect digit in phone number in contact details is enough to kill the LIR? Or house number in the address field ? Or single letter in the contact person’s name? I think that mistakes and typos should be somehow distinguished from cases where falsified documents and data is used. Let’s say after serious mistake RIPE NCC should WARN LIR. Three serious mistakes = closure. Falsified documents = closure. Kind regards, Andrejs Guba
Dear Maria,
Thank you for the announcement.
I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
I would not call this 'wording changes':
$ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership?
Thank you.
-- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
_______________________________________________ members-discuss mailing list members-discuss@ripe.net https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members-discuss/lir%40private.lv
On Wed, Apr 03, 2019 at 06:32:06PM +0300, Andrejs Guba wrote:
I think that mistakes and typos should be somehow distinguished from cases where falsified documents and data is used. Let’s say after serious mistake RIPE NCC should WARN LIR. Three serious mistakes = closure. Falsified documents = closure.
I've yet to hear of a case where the NCC deregistered/closed a LIR without giving it ample oportunity to correct any incorrect data. This does not mean it *couldn't* though, the contract language provides for it another interesting insertion into ripe-716: "In the event a Dutch authority orders the RIPE NCC to deregister specific Internet number resources, the RIPE NCC may comply without following the process or the timeframes described above." Note that this does not mention any court orders. One wonders who the "Dutch authorities" are that can order the NCC to dereg resources... Police? Amsterdam Dog Warden? BREIN? rgds, SL
Kind regards,
Andrejs Guba
Dear Maria,
Thank you for the announcement.
I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
I would not call this 'wording changes':
$ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership?
Thank you.
-- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
_______________________________________________ members-discuss mailing list members-discuss@ripe.net https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members-discuss/lir%40private.lv
_______________________________________________ members-discuss mailing list members-discuss@ripe.net https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members-discuss/ripe-md%40c4inet.net
Hi All,
3 апр. 2019 г., в 18:55, Sascha Luck [ml] <ripe-md@c4inet.net> написал(а):
On Wed, Apr 03, 2019 at 06:32:06PM +0300, Andrejs Guba wrote:
I think that mistakes and typos should be somehow distinguished from cases where falsified documents and data is used. Let’s say after serious mistake RIPE NCC should WARN LIR. Three serious mistakes = closure. Falsified documents = closure.
Yes, definitely! There must be compelling reasons for closing a membership. And this decision must be preceded by a specific warning (penalty). In addition, cases of forgery (photoshop, fabricated registration documents, etc. ..) and unintentional errors should be treated differently. That is - incorrect data is not equal to falsification! For example, when the end-user sends a scan PI-agreement signed by the person that is not in the founding documents (head of department)? Will this be considered a violation? Or in the agreement clearly shows that the signature is a facsimile and not a real handwritten signature? It is indicated that the agreement is valid in electronic form. Is this a violation? In general, we need a simple and transparent rules describing the purpose of penalties. Perhaps it will be good practice to make public information about the penalty on ripe.net web-site and/or create a certain grade scale for each LIR. And of course, such steps must be slow, gradual and accurate. No hurry!
I've yet to hear of a case where the NCC deregistered/closed a LIR without giving it ample oportunity to correct any incorrect data. This does not mean it *couldn't* though, the contract language provides for it :)) That is exactly what happened to us ... We would like to be able to explain without referring to the procedure of Arbitration, but unfortunately we were not given such an opportunity.
another interesting insertion into ripe-716:
"In the event a Dutch authority orders the RIPE NCC to deregister specific Internet number resources, the RIPE NCC may comply without following the process or the timeframes described above."
Note that this does not mention any court orders. One wonders who the "Dutch authorities" are that can order the NCC to dereg resources... Police? Amsterdam Dog Warden? BREIN?
It could be funny if it were not so sad, right now we are seeing the RIPE NCC becoming the REGULATOR instead of the COORDINATOR. Considering the latest offers from the RIPE NCC about BGP hijacks, this is similar to how government structures (RKN) operate in Russia. P.S. sorry for my clumsy english ... — regards, Nikolay Gorstkin
rgds, SL
Kind regards,
Andrejs Guba
Dear Maria,
Thank you for the announcement.
I'm moving the discussion to members-discuss.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
I would not call this 'wording changes':
$ diff ripe697 ripe716 7c7 < The Member repeatedly provides falsified data or information, or purposefully and/or repeatedly provides incorrect data or information (for example, falsified registration documents or IDs, incorrect/inaccurate contact details, etc.). ---
The Member provides falsified or misleading data or information (for example, falsified registration documents or IDs), or repeatedly provides incorrect data or information (for example, incorrect/inaccurate contact details). 11c11 < The Member submits repeatedly fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
The Member submits fraudulent requests for Internet number resources (for example, providing incorrect purpose/need or falsified information about the network, etc.).
So the word 'repeatedly' disappear and in case of _any_ only document mistake, deliberately or not made by the member, the RIPE NCC can call this 'misleading data' or 'fraudulent request' and terminate the membership?
Thank you.
-- Kind regards, Sergey Myasoedov
On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:
Dear Colleagues,
The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has recently been reviewed and updated. The following is an overview of the amendments made.
Section A.1.1 was amended to include situations where both the Member and the RIPE NCC agree to terminate the SSA before the usual three month period has passed. Other changes were made to avoid duplication of information.
Section B.2 was updated to specify certain conditions under which a three month timeframe for deregistration of either Member or End User resources would be unreasonable.
The wording in Section B.2.1 was amended to clarify that during the deregistration process the Member is not allowed to make new announcements using the resources to be deregistered, and that the RIPE NCC will update the maintainer on all the Member's resource objects - not just on the inetnum object.
Section B.2.2 was amended to bring about alignment of the procedures for the deregistration of End User and Member resources and to clarify that if an End User does not have a sponsoring LIR when the deregistration procedure is initiated, they must first establish a contractual relationship with one before they can object to that procedure.
Other amendments were carried out to align the wording of specific sections with the wording used in the rest of the document, the RIPE NCC Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other RIPE NCC procedural documents (Section A.1.1). Similarly, changes were made to reflect changes in the RIPE Database (both operational and structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and B.1.c).
Please see here the relevant link: https://www.ripe.net/publications/docs/ripe-716/
Kind regards,
Maria Stafyla Legal Counsel RIPE NCC
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On Thu, Apr 04, 2019 at 10:40:01AM +0300, Nikolay Gorstkin wrote: Dear Nikolay,
Considering the latest offers from the RIPE NCC about BGP hijacks, this is similar to how government structures (RKN) operate in Russia.
If you are referring to 2019-03 policy proposal, I would like to stress that this is discussed in the RIPE (not RIPE NCC) Anti-Abuse WG. Please, do not confuse RIPE and RIPE NCC. Piotr -- Piotr Strzy�ewski Silesian University of Technology, Computer Centre Gliwice, Poland
Dear Piotr, Yes, you are right. I was wrong of course — regards, Nikolay Gorstkin
4 апр. 2019 г., в 10:54, Piotr Strzyzewski <Piotr.Strzyzewski@polsl.pl> написал(а):
On Thu, Apr 04, 2019 at 10:40:01AM +0300, Nikolay Gorstkin wrote:
Dear Nikolay,
Considering the latest offers from the RIPE NCC about BGP hijacks, this is similar to how government structures (RKN) operate in Russia.
If you are referring to 2019-03 policy proposal, I would like to stress that this is discussed in the RIPE (not RIPE NCC) Anti-Abuse WG. Please, do not confuse RIPE and RIPE NCC.
Piotr
-- Piotr Strzy�ewski Silesian University of Technology, Computer Centre Gliwice, Poland
On Thu, 4 Apr 2019, Nikolay Gorstkin wrote: (...)
It could be funny if it were not so sad, right now we are seeing the RIPE NCC becoming the REGULATOR instead of the COORDINATOR. Considering the latest offers from the RIPE NCC about BGP hijacks,
Hello, Just a small clarification: 2019-03 is merely a proposal currently under discussion. Perhaps i missed that, but within the 350+ messages during the discussion i'm still to see someone argue that persistent intentional hijacks are something tolerable. The NCC's Coordination work is very useful (can't really live without stat.ripe.net nowadays), but part of that great job is being continuously descredited when some people *persistently* annouce address space (or ASNs) that belongs to others -- it doesn't only disrupts legitimate owners communications but also networks that receive such ilegitimate announcements. In the same way there are consequences for people which persistently falsify documents, maybe those consequences should also be applied to those falsifying route announcements. And one very important detail: it shouldn't be the NCC's role to determine if any specific persistent intentional hijack has happenned. While several types of Abuse can't be considered as such in the full extent of RIPE NCC's service region, i think Hijacks are a minimum common denominator that can be agreed by everyone as untolerable. (...)
regards, Nikolay Gorstkin
Best Regards, Carlos
participants (8)
-
Andrejs Guba -
Carlos Friaças -
Maria Stafyla -
Nikolay Gorstkin -
Piotr Strzyzewski -
Sascha Luck [ml] -
Sergey Myasoedov -
Taras Heichenko