Hi Michael Thank you for your exceptionally thorough and operationally grounded analysis. Input of this caliber from an active Security Operations Center and Digital Crimes Unit is invaluable. It has taken me two days and a lot of deep thinking, but I believe I have addressed all your points. My responses are attached below. cheers denis Retired RIPE Database senior analyst & engineer On Tue, 13 Oct 2026 at 19:24, Michael Duffy via Security-wg < security-wg@ripe.net> wrote:
Please find attached Excedo Networks AB’s comments on proposal 2026-02, reviewed by Excedo Security Operations Center.
Drawing on our round-the-clock abuse investigations, coordination with law enforcement, and legal escalation work, we support stronger accountability but consider substantial revisions necessary before adoption.
Our response addresses evidentiary standards, effective mitigation, proportionality, and procedural safeguards.
We particularly highlight active ASNs and associated prefixes operating under unverifiable or struck-off entities, and the need to remove ROA deletion as standalone proof of remediation.
We welcome further discussion with the proposer and the working group.
*Excedo Networks AB* Michael Duffy, CEO/CISO _________________________________________________________________________ Excedo Networks AB – Jan Stenbecks Torg 17, 164 40 KISTA, SWEDEN <https://www.google.com/maps/search/Jan+Stenbecks+Torg+17,+164+40+KISTA,+SWEDEN?entry=gmail&source=g>
Telephone: +46-8-5016 12 00 Email: michael.duffy@excedo.se
Web: www.excedo.se
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