Even more: pushing the red button means the member of NCC is in a big distress and asks for your help. I suggest NCC should protect their members and by all possible means, even in disputes with governments. The right way to do this is limit the comply to Dutch court decisions only. On Wed, 30 Aug 2023 19:18:09 +0300 Vitalii Zubok <vit@visti.net> wrote:
On 30.08.2023 18:39, Svitlana Tkachenko via ncc-services-wg wrote:
Hello!
I support the proposed policy allowing preventive and voluntary locking of IP resources.
However, some definitions seem too vague to me. Could you give more details?
1) "If the RIPE NCC receives a legally binding decision/order related to Internet number resources under a Lock, to Internet number resources under a Lock, the RIPE NCC will have to comply with the order."
Could you please clarity: What steps does RIPE NCC take when it receives such decision/order?
I'd like to support this question.
I would like to draw your attention to the following contradiction. On the one hand, Voluntary Transfer Lock is designed to prevent the forced transfer (primarily) of Ukrainian resources to the occupiers. On the other hand, RIPE NCC, in violation of international, European and national law, recognizes as legitimate the documents issued by the occupation authorities in the Ukrainian regions captured by the Russian army.
This actually means that the condition of receiving "a legally binding decision/order" from the occupied territories makes it possible to violate the lock and defeats its purpose.
This conflict must be resolved before final adoption of Voluntary Transfer Lock policy.
Regards,
Vitaly Zubok UA.VISTI
Will the holder receive a copy of the decision/order?
2) "The RIPE NCC might also not be able to enforce the Lock if it is against any applicable laws or regulations."
"These situations may have practical and/or legal reasons, although the RIPE NCC should keep the number of exceptions as small as possible."
What practical reason can you foresee?
3) At least 1 month before the lock expires, the RIPE NCC should notify the resource holder with the option to extend it or enter into a new locking agreement.
The RIPE NCC not only should send notification but also make sure that it is received. And get a comprehensive answer on the need to cancel the Voluntary Transfer Lock.
4) When applying for a Transfer Lock does the holder need to specify the reason for this status? It can help to analyze the applicability of the Policy and revise if needed.
Kind regards, Svitlana
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