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Summary of Proposal

A framework is proposed as the basis for rigorous maintenance of registration data and for delivery of registry services to legacy Internet resource holders in the RIPE NCC service region.

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[Following text will result in a new RIPE Policy Document “RIPE NCC Services to Legacy Internet Resource Holders“]

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This proposed framework establishes the principles to be applied by the RIPE community in offering and implementing registry services for legacy Internet resource holders. The importance of maintaining accurate records in the RIPE database is recognised as principal. the NCC's principal task.  The community of legacy Internet resource holders is defined. Some rights of members of this community are described, as are the principles governing the manner in which the RIPE NCC should engage with and provide services to this community.

 

delete: <b> 1.0 1.0  Introduction and Definitions delete: </b>

The principal purpose of the RIPE NCC is to maintain an accurate Internet resources obtained prior to or otherwise outside the current hierarchical Internet Registry System (involving the RIPE NCC or any of the other Regional Internet Registries) are considered legacy resources. The RIPE NCC maintains and publishes registry of Internet IP number and AS resources in the RIPE service region: Europe, the Middle East, and Central Asia. To this end, the RIPE NCC maintains a registry (the 'RIPE database') of data for resources held by both its members and legacy resource holders. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> Members delete: </b> are those local Internet registries (LIRs) who have signed a contract for services and pay recurring fees to the RIPE NCC for those services. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> Legacy resource holders delete: </b> are those (natural or formal persons) who hold Internet resources assigned before the creation of the RIPE NCC; these have not signed contracts for services for those resources and have not paid corresponding fees. delete: </p> delete: <p> The RIPE NCC maintains accurate registry data for both member resources and legacy resources. In respect of these data, it provides as delete: <b> basic services: delete: </b> the means for resource holders to maintain the registry data relating to their resources; publication, via delete: <i> whois delete: </i> and related services, of this data; and the provisioning of relevant delegation records in the reverse DNS. delete: </p> delete: <p> In addition, the RIPE NCC provides, or may provide, delete: <b> additional services delete: </b> complementing these basic services. delete: </p> delete: <p> Legacy resource holders are willing to contribute to the costs of the services which they use. In addition, provision of new services, such as certification of legacy resources is a desirable goal, and it is understood that such services will have costs. delete: </p> delete: <p> This proposal outlines a framework under which by legacy resource holders may become first class citizens of the family which they founded in the distant past, and pay the reasonable costs of the services which they use. delete: </p> delete: <p>   delete: </p> delete: <h3> 2.0   Legacy Internet Resources and the RIPE Database delete: </h3> delete: <p> delete: <b> 2.1   RIPE NCC as RIR delete: </b> delete: </p> delete: <p> The located in the RIPE NCC service area. It strives to maintain the accuracy of these data.  The RIPE NCC also provides reverse DNS delegation and a routing registry function of RIPE NCC was originally defined in RIPE-19 [2]: delete: </p> delete: <p> "The RIPE NCC will function as a `Delegated Registry' for IP numbers in Europe, as anticipated and defined in RFC 1174.” delete: </p> delete: <p>   delete: </p> delete: <p> address and Autonomous System Numbers, both of which include legacy resources. insert: </p>

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Historically, legacy resource holdings have been kept outside any 2.2   Responsibility of RIR to maintain registry delete: </p> delete: <p> The responsibility of RIPE NCC to maintain a registry of Internet resources, both for formal relationship between their holders and the RIPE NCC, even in insert: <b> insert: </b> cases where such a relationship covers other resources allocated held by RIPE NCC itself and legacy resources, is acknowledged in RIPE-508 [3]: delete: </p> delete: <p> "The responsibility for record keeping covers Internet number resources allocated to the RIPE NCC by the IANA, as well as Internet number resources that were distributed in the RIPE NCC region by the IANA prior to the RIPE NCC's existence. These resources are known as Early Registration Transfers (ERX), or legacy space." delete: </p> delete: <p>   delete: </p> delete: <p> the 2.3   Benefit of this registry not only to resource holder but to community delete: </p> delete: <p> The maintenance and publication of accurate same holder. To improve the accuracy and trustworthiness of the insert: <b> insert: </b> registry data for each Internet resource provide necessary information for the RIPE NCC and a number of essential network-management activities, including technical troubleshooting and response to incidents of abuse.  Availability of this data is thus of benefit to the Internet community as a whole, and not just to the holder of the resource. delete: </p> delete: <p> In view of this benefit, neither deliberate removal of nor refusal to allow legitimate updates to registry data should be considered. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 2.4   Joint responsibility between RIR and resource holder for quality of data delete: </b> delete: </p> delete: <p> The joint responsibility for keeping the registry data correct and up to date is recognised in RIPE-508 [3]: delete: </p> delete: <p> "The RIPE NCC has the responsibility for keeping the Registry comprehensive, correct and up-to-date. To do this, the RIPE NCC relies on Resource Holders to supply data that pertains specifically to the Resource Holder, as documented in the RIPE NCC Standard Services Agreement [ripe-435] and/or the Independent Assignment Request and Maintenance Agreement [ripe-462]. For holders of legacy resources this responsibility is derived from the original allocation by the IANA Internet Registry." delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 2.5   Requirement on RIR not to obstruct application of updates by holder delete: </b> delete: </p> delete: <p> The RIR must not obstruct the application of legitimate updates to legacy resource data. It must continue to provide means to authenticate access to holders insert: <b> insert: </b> have indicated that a formal relationship is desirable. insert: </p>

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Some of the legacy holders are also interested in a more formal relationship which would give clarity regarding services and allow them to participate in the RIPE NCC's cost-sharing model. insert: </p>

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This framework defines the basis for rigorous maintenance of registration data and for delivery of registry services to legacy Internet resource holders in the RIPE NCC service region. insert: </p>

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insert: <b> 1.1 Definitions insert: </b> insert: </p>

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The following definitions apply in this policy and are of particular importance to the understanding of the goals described in this document. insert: </p>

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insert: <b> Internet Resource: insert: </b> An IP address block or Autonomous System number. insert: </p>

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insert: <b> Legacy Internet Resource: insert: </b> Any Internet Resource obtained prior to or otherwise outside the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries. insert: </p>

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insert: <b> Legacy Internet Resource Holder: insert: </b> The holder of a Legacy Internet Resource. Either by receiving insert: <b> insert: </b> these resources directly or by receiving (part of) Legacy Internet insert: <b> insert: </b> Resources from a Legacy Internet Resource Holder. insert: </p>

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insert: <b> Registry Services: insert: </b> Services provided by the RIPE NCC in its capacity as a Regional insert: <b> insert: </b> Internet Registry, including the following and such additional insert: <b> insert: </b> services as may be identified from time to time as registry services: insert: </p>

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  • Maintenance of data relating to Internet Resources by the NCC in their Internet Resource registry; insert: </li>
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  • Access to these data for update by or on behalf of the holder, and so protect against abusive updates. respective holder; insert: </li>
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  • Public availability of registration data; insert: </li>
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  • Certification of these data; and insert: </li>
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  • Delegation of reverse DNS to the registered DNS servers. insert: </li>
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insert: <b> Registry Service Element: insert: </b> In practice, any Legacy Resource Holder actually avails of a subset of the Registry Services mentioned above.  Where it is necessary to distinguish between the entire class of Registry Services and the specific Registry Services actually provided in a particular case, the latter are described as Registry Service insert: <b> insert: </b> Elements. insert: </p>

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insert: <b> 1.2 Scope insert: </b> insert: </p>

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The framework described in this document applies to the provision of Registry Services by the RIPE NCC in respect of Legacy Internet Resources. Any other services offered by the RIPE NCC (whether different in nature, or relating to other kinds of resources) are out of scope for this policy. insert: </p>

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This scope of this policy does not include the resolution of any dispute arising as to the right to use a particular Legacy Internet Resource. insert: </p>

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Although specification of charges made by the RIPE NCC is also out of scope here, the appropriate kind of charge corresponding to a specific set of circumstances is identified where this seems useful for clarity.

 

3.0   Rights and Obligations of Legacy Internet Resource Holders 2.0 Relationship between Legacy Internet Resource Holder and RIPE NCC

A direct or indirect contractual relationship between a Legacy Internet Resource Holder and the RIPE NCC provides contractual certainty to both parties regarding services, rights, and responsibilities.  Such a relationship also provides for payment of appropriate fees for services provided by the RIPE NCC. Different methods for establishing such a relationship are described below in sections 2.1, 2.2, 2.3, and 2.4. insert: </p>

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In exceptional cases where the Legacy Resource Holder wishes to engage with the RIPE NCC but none of the methods just mentioned is feasible, section 2.5 will apply. insert: </p>

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Section 2.6 below applies in all other cases. insert: </p>

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3.1   Rights pre-date formation of RIRs 2.1 Legacy Internet Resource Holder is already a RIPE NCC member

Legacy Internet resources were assigned directly to their original holders either If the Legacy Internet Resource Holder is already a RIPE NCC member then there is already a contractual relationship between the RIPE NCC and the Resource Holder, who may extend the existing contract by IANA itself or by a global Internet registry acting under IANA's delegated authority prior to the formation of any of the regional Internet registries.  The rights and obligations of the current holder of any such resource are restricted only by the terms of the original direct assignment, except in case the resource holder registering the Legacy Internet Resources involved subject to the conditions defined in section 3 below. insert: </p>

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In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being has freely exercised the right to surrender the resource. delete: </p> delete: <p> The following subsections (3.2 — 3.7) identify, but in force. insert: </p>

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insert: <b> 2.2 Option to become a RIPE NCC member insert: </b> insert: </p>

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A Legacy Internet Resource Holder who is not exhaustively, those rights already a RIPE NCC member may opt to become a member by establishing a membership contract under which must the Legacy Internet Resources involved will then be understood, in the absence of contemporary documentation relating to the original assignment, to be enjoyed by legacy Internet resource holders with respect to the legacy resources which they hold. registered subject to the conditions defined in section 3 below.

In case such documentation is available, the conditions therein specified as to the rights and obligations of the resource holder shall have force. In case the originally specified conditions make provision this case, the RIPE NCC may require the payment of charges for the conditions to be amended and amendments have been made membership and services according to such provision, the most recently amended version of the conditions as to rights and obligations shall have force. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.2   Right to use delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, legacy Internet resources may be used as their holders see fit. This includes, but is not restricted to their use as end-point and routing identifiers on the global public Internet. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.3 Right to exercise responsibility for quality of data delete: </b> delete: </p> delete: <p> In any case, the holder of a legacy resource shall have the right to exercise the responsibility mentioned in subsection 2.4 above. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.4   Right of succession delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, legacy Internet resources may be inherited and assigned. delete: </p> delete: <p> A legacy Internet resource holder may be subject to merger, acquisition, or change in legal personality.  A legacy Internet resource holder who is a natural person will sooner or later suffer death. delete: </p> delete: <p> In such an event, that holder's heir, successor, or assign (as the case may be) shall immediately after the event enjoy the same rights and be subject to the same obligations with regard to each legacy Internet resource involved as the prior holder enjoyed or was subject to immediately before the event. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.5   Right of transfer delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, the holder the RIPE NCC charging plan for the time being of a legacy Internet resource may transfer or sell that resource. delete: </p> delete: <p> In such an event, the recipient of the resource shall immediately after the event enjoy the same rights and be subject to the same obligations with regard to each legacy Internet resource involved as the prior holder enjoyed or was subject to immediately before the event. delete: </p> delete: <p> in force. insert: </p>

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3.6 Right of surrender delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, the holder for the time being of any legacy Internet resource is free to surrender the resource irrevocably at any time and at the holder's sole discretion either directly to IANA or to the Regional Internet Registry of the holder's choice. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.7   Freedom from obligations delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, the holder for the time being of a legacy Internet resource  is not subject to any obligations in relation to the resource. delete: </p> delete: <p>   delete: </p> delete: <h3> 4.0   Engagement with Holders of Legacy Internet Resources delete: </h3> delete: <p> When engaging with the holders of legacy Internet resources, communications from the RIPE NCC should be transparent, so that all parties understand the full situation, and should have respect for any existing relationships between legacy resource holders and NCC members so that the most appropriate contact channel can be used (be that directly or via an existing LIR.) delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.1   Transparency: delete: </b> delete: </p> delete: <p> delete: <b> 4.1.1   Acknowledgement of rights delete: </b> delete: </p> delete: <p> RIPE NCC acknowledges that it has no authority to curtail or modify the rights or obligations of the holder of any legacy resource with regard to that resource. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.1.2   Disclosure of options delete: </b> delete: </p> delete: <p> All options available to the legacy resource holder should be disclosed in the initial communication, including those specified in section 5.0. Any difference from the services currently provided to a legacy resource holder should be described. Charges for each option and corresponding services should be clearly described. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.1.3   Offer of additional services delete: </b> delete: </p> delete: <p> Additional services, if any, offered by an RIR only to a member or through a member as intermediary, and which have not  historically been available available to non-members,  may also be described and offered. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.2 Respect delete: </b> delete: </p> delete: <p> delete: <b> 4.2.1 No coercion delete: </b> delete: </p> delete: <p> Legacy Resource Holders may not be rushed or coerced into a quick decision because of urgent operational needs. delete: </p> delete: <p> In particular, when the holder of legacy Internet resource requires the data for that resource to be updated for pressing operational reasons, the RIR must not seek to impose the conclusion of a (direct or indirect) contractual relationship as a precondition to accepting the update. delete: </p> delete: <p> Each legacy resource holder who has agreed to terms with the RIPE NCC prior to the adoption of this policy must be individually contacted and offered terms consistent with this policy, without the establishment of any deadline to produce a decision. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.2.2   Contact via LIR using apparent existing relationships delete: </b> delete: </p> delete: <p> The objective of reliable registration data is most likely to be met if the RIPE NCC uses the help of its existing members to contact legacy resource holders with whom there is an apparent relationship. delete: </p> delete: <p> A phased procedure should be followed similar to that followed in the implementation of RIPE-452. Existing members who contact their legacy holder customers should be given adequate information to describe the available options to their customers, and offer the appropriate services (such as registration through a sponsoring LIR) where preferred. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.2.3   Contact directly only in last resort delete: </b> delete: </p> delete: <p> Consistent with phase 3 of the implementation of RIPE-452 for Provider-Independent space holders, the holders of legacy resources that cannot be associated with a likely sponsoring LIR should be contacted directly by the RIPE NCC. delete: </p> delete: <p>   delete: </p> delete: <h3> 5.0   Services for Legacy Internet Resource Holders delete: </h3> delete: <p> delete: <b> 5.1   Reasonable conditions delete: </b> delete: </p> delete: <p> delete: <b> 5.1.1 Maintenance of rights delete: </b> delete: </p> delete: <p> No offer by the NCC of service to the holder of any legacy Internet resource, whether directly or through a sponsoring LIR, may be subject to a condition of waiver or surrender of any of the holder's rights in respect of that resource. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.1.2 Protection against abuse of RIR monopoly delete: </b> delete: </p> delete: <p> No basic service which is required to support the effective use of a legacy Internet resource may be withdrawn or withheld from the holder of that resource unless an equivalent service is available at a cost which is reasonably justifiable by reference to current market availability of comparable services. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.2   2.3 Option to engage via sponsoring LIR

The holder of a legacy Internet Resource shall have the option of obtaining NCC services in respect of that resource via a sponsoring LIR. This option will require the signing of a A Legacy Internet Resource Holder who either is not already a RIPE NCC member or, being a member, does not wish to extend the membership contract as provided in section 2.1 above may opt to enter into a contract with a RIPE NCC member who is willing to act as a Sponsoring LIR for the purposes of registering the Legacy Resources involved, subject to the conditions defined in section 3 below, and subject to approval by the RIPE NCC of the form of contract between the sponsoring Resource Holder and the Sponsoring LIR. insert: </p>

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In this case, the Sponsoring LIR and the holder of the resource, describing may require the payment of charges according to the terms of the contract agreed with the Legacy Resource Holder. insert: </p>

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insert: <b> 2.4 Option to engage directly with the RIPE NCC insert: </b> insert: </p>

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A Legacy Internet Resource Holder whose circumstances match those described in section 2.3 above, but cannot find a Sponsoring LIR with which services will be provided.  The a mutually satisfactory contract must explicitly acknowledge of the kind mentioned in that the rights and obligations of the section, may opt to enter a non-member service contract with the RIPE NCC for the purposes of registering the Legacy Resources involved, subject to the conditions defined in Section 3 below. insert: </p>

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In this case, the RIPE NCC may require the payment of reasonable charges according to the terms of the non-member service contract. insert: </p>

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insert: <b> 2.5 When there are obstacles for 2.1/2.2/2.3/2.4 insert: </b> insert: </p>

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Due to specific enduring or temporary circumstances which are recognised by the RIPE NCC as being outside the resource holder's control, a legacy Internet resource holder with regard to the may be unable to enter into a relationship of any of the kinds described above (2.1, 2.2, 2.3, 2.4).  In such a case, the RIPE NCC will offer and provide registry services as if a contractual relationship of one of the kinds described above had been established, and shall do so for as long as the circumstances continue which constitute an obstruction to the establishment of a contract.  insert: </p>

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However, notwithstanding the preceding paragraph, the RIPE NCC may refuse to provide any specific registry service for which particular technical requirements apply, which the Resource Holder is unable to meet. insert: </p>

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insert: <b> 2.6 No relationship insert: </b> insert: </p>

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In cases where the current holder of Legacy Internet Resources cannot be contacted, does not reply to contact from the RIPE NCC or is unknown,  there is no formal relationship between the holder and the RIPE NCC. insert: </p>

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In such a case, the RIPE NCC insert: </p>

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- will continue to provide any registry service element already provided in support of each Legacy Internet Resource involved; insert: </p>

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- will have no obligation to begin to provide any registry service element not already provided in support of a particular Legacy  Internet Resource, even in case the service element is provided in  support of any other Legacy Internet Resource held by the same or another Resource Holder; insert: </p>

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- and may update the related entries in the RIPE Database from time to time to correspond to the current actual situation. insert: </p>

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3.0 Contractual requirements insert: </h3>

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The service agreement covering registration of a legacy resources involved remain unchanged as they were prior to conclusion of the contract. delete: </p> delete: <p> The sponsoring Internet resource between the corresponding Resource Holder and either the Sponsoring LIR will be responsible for declaring the existence or the RIPE NCC must include insert: </p>

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  •  identification of each such contract concluded with a legacy Internet resource covered by the service agreement; insert: </li>
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  •  specification of the service or services offered in respect of each resource identified; insert: </li>
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  •  a statement of the responsibility of the resource holder to the RIPE NCC and also for giving sight of the contract to the RIPE NCC if so requested. delete: </p> maintain accurate data in the registry in respect of each resource identified; insert: </li>
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  • acknowledgement that the terms and conditions under which the resources were originally granted are outside the scope of, and unchanged by, the service agreement. insert: </li>
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delete: <p> delete: <b> 5.3 Option to become a RIPE NCC member delete: </b> delete: </p> delete: <p> The holder of a legacy Internet resource shall have the option of becoming a member of the RIPE NCC.  The contract for membership and service must explicitly acknowledge that the rights and obligations of the legacy Internet resource holder with regard to each legacy resource involved remain unchanged as they were prior to conclusion of the contract. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.5 Recommendations as to charging for services delete: </b> delete: </p> delete: <p> Current market prices for a comparable service must insert: <h3>

4.0 Services to be taken as a point of reference in identifying the reasonable cost of a service offered by the RIPE NCC in respect of a legacy Internet resource. delete: </p> delete: <p> It is noted that, as of August 2012, commercial domain-name registrars are able to and provided insert: </h3>

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The RIPE NCC will offer and provide services comparable to the basic services in respect of a given Legacy Internet Resource corresponding to the relationship established with the holder of that resource. insert: </p>

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In the case of any of the forms of relationship described in sections 2.1, 2.2, or 2.3 above, this policy shall not exclude any service from being offered and/or provided in respect of a Legacy Internet Resource registered under the terms of the corresponding direct or indirect contractual agreement relationship with the RIPE NCC. insert: </p>

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In the case of any of the forms of relationship described in sections 2.1, 2.2, 2.3, or 2.4 above, the RIPE NCC shall offer Registry Services as defined in section 1.1 above at a tax-inclusive retail price of in respect of each Legacy Internet Resource involved and as requested by the corresponding Resource Holder. insert: </p>

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In case the situation corresponds to section 2.6 above, the RIPE NCC shall maintain each Registry Service already provided in respect of any corresponding Legacy Internet Resource. insert: </p>

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5.0 Arbitration in case of conflict insert: </h3>

insert: <p>

In case of conflict between a Legacy Internet Resource Holder and the RIPE NCC about twenty euro. delete: </p> delete: <p> In the case that the holder of a legacy Internet resource opts to engage via a sponsoring LIR and wishes to avail only of basic services as defined above, assessment of the billing category of the sponsoring LIR should take account of the legacy resource using a score or rate less than that applicable for a corresponding PI resource. delete: </p> delete: <p> In the case that the holder of a legacy Internet resource opts to engage via a sponsoring LIR and wishes to avail of additional services as defined above, assessment of the billing category of the sponsoring LIR should take account of the legacy resource using a score no greater than that applicable for a corresponding PI resource. delete: </p> delete: <p> Legacy Internet Resource Holders that choose to become RIPE NCC Members shall any matter within the scope of this policy, the RIPE NCC Conflict Arbitration Procedure is to be charged fees, and enjoy services, in accordance with their RIPE NCC Membership agreement. delete: </p> delete: <p>   delete: </p> delete: <h3> 6.0   Revisions and Extensions to this Policy delete: </h3> delete: <p> delete: <b> 6.1   RIPE NCC may not act in "policy-free zone" delete: </b> delete: </p> delete: <p> The RIPE NCC can develop activities and services for the Internet Community or the RIPE NCC Members without this activity or service being defined in a policy. The management of resources however is a task entrusted to the RIPE NCC by the Internet community. The Memorandum of Understanding with ICANN [5] and specifically the Criteria for Establishment of New Regional Internet Registries [6] state that an RIR must have a "bottom-up self-governance structure for setting local policies". delete: </p> delete: <p> The policies as implemented by the RIPE NCC are developed in the bottom-up Policy Development Process [4]. The RIPE NCC has decided to try to make Legacy Resource Holders sign documents that force them to comply with RIPE policies. While there is no policy that forbids RIPE NCC from doing this, there is also no policy that states that this must be done. RIPE NCC is currently acting in a "policy-free zone" which is following a top-down approach instead of the required bottom-up Policy Development Process. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 6.2   Revised or additional policy required for action not covered by present policy delete: </b> delete: </p> delete: <p> This document proposes a framework for future policies. As soon as there is consensus within the RIPE community on this framework any future policy development must be done within the bounds of this framework. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 6.3   Revision by normal RIPE PDP process delete: </b> delete: </p> delete: <p> As for any RIPE policy this framework is also subject to revision by the RIPE Policy Development Process [5]. However, such future revisions must never restrict the rights of Legacy Resource Holders to their legacy resources. delete: </p> delete: <p>   delete: </p> delete: <h3> 7.0 References delete: </h3> delete: <p> [1] delete: <a class="external-link" href="http://www.bbc.com/news/technology-12859585"> Microsoft spends $7.5m on net addresses delete: </a> delete: </p> delete: <p> [2] delete: <a class="internal-link" href="resolveuid/d33301e2f55bc610b1ef1aad5cec299c" data-val="d33301e2f55bc610b1ef1aad5cec299c" data-linktype="internal"> RIPE Network Coordination Centre delete: </a> delete: </p> delete: <p> [3] delete: <a class="external-link" href="http://www.ripe.net/ripe/docs/ripe-registry"> The RIPE Registry delete: </a> delete: </p> delete: <p> [4] delete: <a class="external-link" href="http://www.ripe.net/ripe/docs/pdp"> Policy Development Process in RIPE delete: </a> delete: </p> delete: <p> [5] delete: <a class="external-link" href="http://aso.icann.org/documents/memorandum-of-understanding/"> ICANN Address Supporting Organization (ASO) MoU delete: </a> delete: </p> delete: <p> [6] delete: <a class="external-link" href="http://www.icann.org/en/news/in-focus/global-addressing/new-rirs-criteria"> ICP-2: Criteria for Establishment of New Regional Internet Registries delete: </a> applied.

 

Rationale

insert: <ul>
    insert: <li>
  • a. Arguments supporting the proposal delete: </p> delete: <p> Since RIPE 63 (Vienna, Oct-Nov 2011), the RIPE NCC has been approaching insert: <br />
    New policy covering provision of services to legacy resource holders and offering them the opportunity to have the data held by the NCC in relation to their is needed because the scope of existing RIPE policies extends only to Internet resources distributed through the RIPE NCC.  Such new policy will support the RIPE NCC in addressing what RFC 2050 describes as the "primary function" of a Regional Internet Registry and will give legacy Internet resource holdings updated to ensure accuracy of the records, on terms opportunistically imposed by the NCC.  There was as yet no RIPE policy in place to support this initiative.  Furthermore, the NCC began the activity without first engaging in consultation with the affected resource holders.  Consequently, the activity was perceived by many of those affected as inappropriate and leading to a “destruction of trust”. delete: </p> delete: <p> This policy proposal is made in an attempt to recover the unfortunate situation which has arisen and  in the hope that it will help prevent such a situation arising again. delete: </p> delete: <p> Although IPv4 addressing resources were not originally intended to be object of any kind of trade, practice showed otherwise during the last years [1]. The implicit acceptance of trade practices over IPv4 addresses sets the background holders clarity as to the services they may expect. insert: </p>

    insert: <p>

    Extensions to the RIPE NCC service model are proposed because of the need for any organisation to consider their legacy Internet resources as an asset, which can be potentially traded. delete: </p> delete: <p> delete: <br /> delete: <b> b. Arguments opposing the proposal delete: </b> delete: </p> delete: <p> As a "public registry" (rather than a members-only registry) identified in RFC 2050. insert: </p>

    insert: <p>

    [and as may be received during Discussion Phase. delete: </p> the discussion phase] insert: <br />
    insert: <br />
    insert: </p>

    insert: </li>
  • insert: <li>
  • insert: <p>

    insert: <b> Arguments opposing the proposal insert: </b> insert: <br />
    Extensions to the RIPE NCC service model are proposed. insert: </p>

    insert: <p>

    [and as may be received during discussion phase] insert: </p>

    insert: </li>
  • insert: </ul>

 

insert: <hr />
insert: <p>

insert: <a name="impact-analysis"> insert: </a> insert: </p>

insert: <h2>

Impact Analysis insert: </h2>

insert: <h3>

Legacy Resources Proposal insert: </h3>

insert: <p>

The RIPE NCC is hereby publishing an initial impact analysis based on its interpretation of the policy proposal text. This analysis is also intended to highlight the need for more guidance and information from the community in defining a number of fundamental pre-requisites in order to determine the nature of the various implementations, and the impact of the policy proposal itself. insert: </p>

insert: <h3>

Executive Summary insert: </h3>

insert: <p>

Given the length of this analysis, the following Executive Summary presents some of the interpretations and issues the RIPE NCC outlines in a more concise format. For further detail and the reasoning behind these points, please refer to the relevant section in the impact analysis below. insert: </p>

insert: <ol>
    insert: <li>
  1. The proposal refers to the terms and conditions under which the Legacy Internet Resources were originally granted. The RIPE NCC will need to be informed as to the content of these original terms and conditions to properly determine their impact. insert: </li>
  2. insert: <li>
  3. The RIPE NCC often receives requests from Legacy Resource Holders wanting their resources to be considered as space allocated by the RIPE NCC. If this proposal is accepted, the RIPE NCC will have to decline these requests. insert: </li>
  4. insert: <li>
  5. Due diligence checks will be required to verify the legitimacy of Legacy Resource Holders. If the correct documentation cannot be provided, the RIPE NCC will be unable to enter into a contractual relationship with the Legacy Resource Holder. insert: </li>
  6. insert: <li>
  7. Section 2.1 of the proposal allows Legacy Internet Resources to be covered by the RIPE NCC Standard Service Agreement (SSA). Modifications to the SSA will require approval by the General Meeting (GM). insert: </li>
  8. insert: <li>
  9. Section 2.4 of the proposal allows the Legacy Resource Holder to engage directly with the RIPE NCC through a special contract if they cannot find a sponsoring LIR. The RIPE NCC cannot think of any circumstances where this might be the case. Also, the creation of such a special class of contract would require approval by the GM. insert: </li>
  10. insert: <li>
  11. Similarly, section 2.5 allows the Legacy Resource Holder to conclude no contract due to special enduring circumstances. The RIPE NCC cannot think of what these circumstances might be, and some Registration Services cannot be performed without a contract in place. Additionally, the RIPE NCC will be unable to enforce these resource holders to maintain accurate data in the registry. insert: </li>
  12. insert: <li>
  13. In cases where the Legacy Resource Holder is unknown or unresponsive, the proposal allows for the RIPE NCC to update entries in the RIPE Database but does not specify the scope of these updates. insert: </li>
  14. insert: <li>
  15. The provision of some RIPE NCC services is dependent on whether the resources are PA or PI. The RIPE NCC will require clear guidelines on the terms under which Legacy Internet Resources would be offered these services. insert: </li>
  16. insert: <li>
  17. Currently arbitration does not apply to Legacy Internet Resources. Amendments to the arbitration procedure are subject to approval by the GM. insert: </li>
  18. insert: <li>
  19. If the proposal is accepted, the RIPE NCC will have to contact Legacy Resource Holders that have their resources registered under the umbrella of an LIR and offer them the contractual options of the accepted proposal. The RIPE NCC will consider any requests for this since 1992 as having never been submitted. insert: </li>
  20. insert: <li>
  21. If the community decides that this proposal should allow for the certification of Legacy Internet Resources, the RIPE NCC will need to create a certification system specific to these resources. insert: </li>
  22. insert: <li>
  23. The RIPE NCC is seeking guidance from the community on who should be considered the legitimate holder of Legacy Internet Resources that have been distributed through several layers of hierarchy. insert: </li>
  24. insert: <li>
  25. RIPE Database objects referring to Legacy Internet Resources currently have several different "status:" attribute values. The RIPE NCC proposes changing these to 'LEGACY'. insert: </li>
  26. insert: <li>
  27. The RIPE NCC also proposes introducing a mandatory "status:" attribute for all AUT-NUM objects which would take the value 'LEGACY' for all legacy AS numbers. For all other AS numbers the values would either be set to 'ASSIGNED' (assigned by the RIPE NCC) or 'OTHER' (assigned by other RIRs). insert: </li>
  28. insert: </ol>
insert: <p>

  insert: </p>

insert: <h2>

A. Understanding of the Policy Proposal insert: </h2>

insert: <p>

This policy proposal is meant to be applied by the RIPE NCC to Registration Services, as regards Legacy Internet Resources. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Legacy Internet Resources insert: </b> – as defined in this proposal, are any Internet resources obtained prior to (or otherwise outside of) the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries (RIRs). While this definition is not limited to resources in the RIPE Registry, the RIPE NCC does not have authority over Legacy Internet Resources in other registries. If this proposal is accepted, the RIPE NCC will implement it only to Legacy Internet Resources that are currently registered in the RIPE Registry. insert: </p>

insert: <p>

This definition also refers to resources that have been distributed by IANA, InterNIC (or according to the appropriate manner at the time of distribution). This includes Legacy Internet Resources that have been transferred to the RIPE Registry since 1992 and subsequently registered under the umbrella of a RIPE NCC member. insert: </p>

insert: <p>

This definition does not include: insert: </p>

insert: <ul>
    insert: <li>
  • Resources that have been distributed or “obtained” in an inappropriate manner (e.g. hijacked resources). insert: </li>
  • insert: <li>
  • Resources that have been transferred between RIPE NCC members in accordance with section 5.5 of “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, which states: insert: <i> “Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or insert: <b> the IANA insert: </b> … Re-allocated blocks are no different from the allocations made directly by the RIPE NCC and so they must be used by the receiving LIR according to the policies described in this document.” insert: </i> insert: </li>
  • insert: <li>
  • Resources transferred from other RIRs that have lost their “legacy” status due to the relevant RIR policies or processes (provided the RIPE NCC has an inter-RIR transfer policy). insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <p>

insert: <b> Registration Services insert: </b> – as defined in this proposal, are those services provided by the RIPE NCC in its capacity as a RIR. The proposal specifies them as services “ insert: <i> including the following and such additional services as may be identified from time to time as registry services insert: </i> (section 1.1). These services include: insert: </p>

insert: <ul>
    insert: <li>
  • insert: <b> Maintenance of data relating the Internet resources by the RIPE NCC in the RIPE Registry. insert: </b> The RIPE NCC understands this as the service to maintain a comprehensive record of the Internet number resources registered within its service region. insert: </li>
  • insert: <li>
  • insert: <b> Access to these data for update by (or on behalf of) the respective holder. insert: </b> The RIPE NCC understands this as the service of enabling the legitimate holder to update records in the RIPE Registry. The RIPE NCC must ensure that updates are legitimate. For this reason, updates are accepted solely by individuals and organisations authorised by the legitimate holder of the Internet number resource. Access to, and updates of this data can be made by anyone using public tools (such as RIPE Database updates). Additionally, organisations that have entered into a contractual relationship with the RIPE NCC can update this data using member-only tools, such as the LIR Portal.  insert: </li>
  • insert: <li>
  • insert: <b> Public availability of registration data. insert: </b> The RIPE NCC understands this as the service of making registration data available through the RIPE Database. insert: </li>
  • insert: <li>
  • insert: <b> Certification of these data. insert: </b> The RIPE NCC understands this as the service of making Legacy Internet Resources in the RIPE Registry eligible for resource certification (RPKI). insert: </li>
  • insert: <li>
  • insert: <b> Reverse DNS delegation. insert: </b> The RIPE NCC understands this as the service of providing rDNS services to Legacy Internet Resources registered in the RIPE Registry. insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <p>

This definition gives a non-exclusive list of services. Other services, both current and future, may also be considered Registration Services. This proposal does not specify the process according to which a service (other than those listed) is identified as Registration Services. Therefore, this decision will be made by the RIPE NCC, after consultation with the membership and RIPE Community. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Registration Services Element insert: </b> – the term Registration Services Element is solely used in this document when referring to services that the RIPE NCC already provides with regards to Legacy Internet Resources (section 2.6). Therefore, the RIPE NCC understands that this term contains the following services: insert: </p>

insert: <ul>
    insert: <li>
  • Maintenance of data relating to Internet number resources by the RIPE NCC in its Internet resource registry, as defined above insert: </li>
  • insert: <li>
  • Access to these data for update by or on behalf of the respective holder. insert: </li>
  • insert: <li>
  • Public availability of registration data. insert: </li>
  • insert: <li>
  • Reverse DNS delegation. insert: </li>
  • insert: </ul>
insert: <p>

insert: <b>   insert: </b> insert: </p>

insert: <p>

The proposal outlines a number of options for Legacy Resource Holders to enter into a contractual relationship for their resources, so that they can be provided with Registration Services. These options will be analysed in detail below. insert: </p>

insert: <p>

The RIPE NCC would like to highlight that it currently receives requests from Legacy Resource Holders who desire for their resources to be registered and maintained as if they had been distributed by the RIPE NCC (losing their legacy status, and becoming subject to RIPE Policies and RIPE NCC procedures). Over the years, the RIPE NCC has approved a number of these requests on a case-by-case basis. insert: </p>

insert: <p>

However, this proposal does not provide an option for Legacy Internet Resources to lose their legacy status, nor does it allow Legacy Resource Holders to have their resources maintained as if they had been distributed by the RIPE NCC. Therefore, if the proposal is accepted, the RIPE NCC will have to reject any such requests. This is explained further below (Impact on Registration Services – Legacy Internet Resources Registered Under an LIR Umbrella). insert: </p>

insert: <h2>

B. Legal Impact insert: </h2>

insert: <h3>

Contractual Relationship Between Legacy Resource Holder and the RIPE NCC insert: </h3>

insert: <h3>

Legacy Resource Holder insert: </h3>

insert: <p>

If this proposal becomes policy, the RIPE NCC should enter into a contractual relationship with the Legacy Resource Holder or approve a contractual relationship between the holder and a sponsoring LIR. insert: </p>

insert: <p>

This proposal defines the holder of a Legacy Internet Resource as one who has received these resources either directly, or from another Legacy Resource Holder. This definition does not include holders of resources that are not covered by the RIPE NCC’s understanding of the definition of Legacy Internet Resources (see above under Legacy Internet Resources). insert: </p>

insert: <p>

The RIPE NCC is entitled to perform due diligence checks in order to enter into a contract with someone that claims to be a Legacy Resource Holder. These due diligence checks will consist of: insert: </p>

insert: <ul>
    insert: <li>
  • Verification that the contractual party exist (and are valid) and that they are properly represented in the signing of the agreement in accordance with the RIPE NCC procedural document “ insert: <a href="http://www.ripe.net/ripe/docs/ripe-556"> Due Diligence for the Quality of the RIPE NCC Registration Data insert: </a> ”. insert: </li>
  • insert: <li>
  • Verification that the party claiming to be the Legacy Resource Holder is indeed the legitimate holder of the resources. The holder will need to submit the relevant proof and documentation. The RIPE NCC will need to update the above-mentioned due diligence procedural document to clarify the details of this verification process. insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <p>

If a party claiming to be a Legacy Resource Holder is unable to comply with these due diligence checks by providing satisfactory documentation as required, the RIPE NCC will not accept a contractual relationship as described in this proposal. In cases where there is uncertainty about the resource holder, the RIPE NCC will handle these resources as outlined in section 2.6 of the proposal (see Option 6 below). insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <b> Different Types of Contractual Relationship insert: </b> insert: </h3>

insert: <p>

insert: <b> Option 1 (section 2.1) - The Holder is a RIPE NCC Member and Extends the Existing Contract to the Legacy Internet Resources insert: </b> insert: </p>

insert: <p>

If the Legacy Resource Holder has already signed the RIPE NCC SSA, the proposal provides that the SSA may be extended to cover their Legacy Internet Resources as well. However, the SSA must include certain conditions as defined in section 3.0 of the proposal. insert: </p>

insert: <p>

The RIPE NCC offers the same SSA to all of its members. If the proposal becomes policy, the RIPE NCC will have to consider ways to include the extension of the SSA to Legacy Internet Resources in its legal framework. The outlined conditions may require amendments to the SSA, which will require approval by the General Meeting (GM). insert: </p>

insert: <p>

One of the specific conditions required by the policy is the following: insert: </p>

insert: <p>

 “ insert: <i> Acknowledgement that the terms and conditions under which the resources were originally granted are outside the scope of and unchanged by, the service agreement insert: </i> ”. For such a provision to be implemented, the RIPE NCC will have to be aware of the terms and conditions under which these resources were originally distributed, which means the Legacy Resource Holder will need to provide these to the RIPE NCC. insert: </p>

insert: <p>

These terms and conditions may affect the rights and obligations of the Legacy Resource Holder and the RIPE NCC, including the responsibility of the holder to maintain accurate data in the registry, as well as the RIPE NCC’s ability to enforce RIPE Policies and RIPE NCC procedures. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Option 2 insert: </b> insert: <b> (section 2.2) - The Legacy Resource Holder Becomes a RIPE NCC Member insert: </b> insert: </p>

insert: <p>

The same applies as in Option 1. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Option 3 insert: </b> insert: <b> (section 2.3) – The Legacy Resource Holder Enters into a Contract With a Sponsoring LIR insert: </b> insert: </p>

insert: <p>

According to the proposal, this option should be available for non-LIRs as well as for LIRs that do not wish to include their Legacy Internet Resources under their SSA. In the latter case, however, it should be made clear that the RIPE NCC will not allow the Legacy Resource Holder to become the sponsoring LIR for their own Legacy Internet Resources. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Option 4 insert: </b> insert: <b> (section 2.4) – The Legacy Resource Holder Engages Directly with the RIPE NCC with Another Agreement (Not the SSA) insert: </b> insert: </p>

insert: <p>

This option is available for those Legacy Resource Holders that cannot find a sponsoring LIR with which a mutually satisfactory contract can be signed. insert: </p>

insert: <p>

The RIPE NCC, through its experience with the implementation of the proposal 2007-01, firmly believes that holders can always find a sponsoring LIR that is suitable. Additionally, holders always have the option to become members of the RIPE NCC. Therefore, it is difficult to see how a Legacy Resource Holder will not be able to include their Legacy Internet Resources in the SSA or find a sponsoring LIR. If this proposal becomes policy, the RIPE NCC will need to set some minimum transparent standards for an agreement to be considered satisfactory. insert: </p>

insert: <p>

It is also worth noting that in the past the RIPE NCC used to conclude special agreements with Direct Assignment Users, but in 2012 the GM decided to remove special types of contracts and make RIPE NCC services available to members only. Accordingly, the re-creation of a special agreement for RIPE NCC services to non-members will need approval by the GM. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Option 5 (section 2.5) – The Legacy Resource Holder Concludes No Agreement insert: </b> insert: </p>

insert: <p>

According to the proposal, the Legacy Resource Holder may not be required to have an agreement due to specific enduring or temporary circumstances which the RIPE NCC recognises as being beyond the holder’s control. The proposal does not give any examples or indication of what these circumstances may be, so it is at the RIPE NCC’s discretion to decide. However, the RIPE NCC cannot currently identify any special circumstances that would limit the ability of a holder to enter into any of the above agreements (to become member or to find a sponsoring LIR). insert: </p>

insert: <p>

According to the proposal, the RIPE NCC will have to keep providing the services it currently provides to Legacy Resource Holders as if there was a contract in place and should do so for as long as the special circumstances still exist. However, it is not clear what services the RIPE NCC is required to provide. In particular, according to the proposal, the RIPE NCC may refuse to provide specific services for which particular technical requirements apply. Some Registration Services may require a technical (legal) control that cannot be performed without a contract in place. In these cases, the RIPE NCC would be unable to provide services beyond those identified above as Registration Services Elements without a contract. insert: </p>

insert: <p>

The RIPE NCC would like to point out that currently, in order to provide minimum services for Legacy Internet Resources registered in the RIPE Database (not covered by a contract), it applies a due diligence process to verify that the person requesting the service is (or is acting on behalf of) the one registered in the RIPE Database as the Legacy Resource Holder. If this proposal becomes policy, the RIPE NCC will keep applying this due diligence process. Also, the RIPE NCC has no means of enforcing that the resource holder maintains accurate data in the registry. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Option 6 (section 2.6) – The Legacy Resource Holder is Unknown or Unresponsive so No Contractual Relationship can be Concluded insert: </b> insert: </p>

insert: <p>

The proposal describes cases where the Legacy Resource Holder is unknown or cannot be contacted. In this case, the RIPE NCC will have to continue providing any Registration Services Elements that are already provided. The RIPE NCC has defined what it considers to be Registration Services Elements above. insert: </p>

insert: <p>

The RIPE NCC would also like to highlight the case of Legacy Resource Holders that, after the potential approval of this proposal, have concluded a contract with the RIPE NCC or a sponsoring LIR and therefore were provided with more Registration Services. In this case, if the holder’s agreement is terminated and the holder is unresponsive, the RIPE NCC will not be obliged to keep providing the holder with services other than those identified above as Registration Services Elements. insert: </p>

insert: <p>

What was mentioned above, under Option 5, about the due diligence process applied to Legacy Internet Resources registered in the RIPE Database but not covered by a contract, also applies to this option. In addition, the RIPE NCC has no means of enforcing that the resource holder maintains accurate data in the registry. insert: </p>

insert: <p>

The proposal also allows for the RIPE NCC to “update the related entries in the RIPE Database in accordance with the actual situation”. The scope and content of these updates is not specified, so it is at the RIPE NCC’s discretion to decide what this should be. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

Terms for the Provision of Registration Services insert: </h3>

insert: <p>

The provision of some of these services is subject to RIPE Policies and RIPE NCC procedures, and depends on whether the resources are Provider Aggregatable (PA) or Provider Independent (PI). The RIPE NCC should acquire clear guidelines on the terms under which Legacy Internet Resources would be offered these services. Also, it is important to take into account that some of the services mentioned above are only provided with regards to specific kinds of resources (e.g. certification is only available for PA allocations). insert: </p>

insert: <p>

The proposal also refers to specific insert: <i> “terms and conditions under which the resources were originally granted” insert: </i> , which are insert: <i> “outside of the scope of, and unchanged by” insert: </i> a service agreement that refers to Legacy Internet Resources. The RIPE NCC must be informed of the details of these terms and conditions so that the terms for the provision of services to Legacy Resource Holders can be further analysed. insert: </p>

insert: <h3>

Arbitration insert: </h3>

insert: <p>

Currently arbitration does not apply to Legacy Internet Resources. If this proposal is accepted, the RIPE NCC arbitration procedure will have to be updated. Amendments to the arbitration procedure are subject to approval by the GM. insert: </p>

insert: <h3>

C. Impact on Registration Services insert: </h3>

insert: <p>

insert: <b> Legacy Internet Resources Currently Registered Under an LIR Umbrella insert: </b> insert: </p>

insert: <p>

As mentioned above (Understanding of the Proposal– Legacy Internet Resources) the proposal includes Legacy Internet Resources that have been transferred to the RIPE Registry since 1992 and subsequently registered under the umbrella of a RIPE NCC member. insert: </p>

insert: <p>

Between 1992 and 2011, the RIPE NCC has, at the request of holders, registered Legacy Internet Resources, under the umbrella of an LIR on an ad-hoc basis, without entering into a contractual relationship for these resources. insert: </p>

insert: <p>

Between January 2012 and August 2012, the RIPE NCC has accepted statements by Legacy Resource Holders agreeing that their resources are to be considered as having been distributed by the RIPE NCC, and therefore losing their legacy status. These resources have been registered under the umbrella of an LIR at the holders’ request. insert: </p>

insert: <p>

If this proposal becomes policy, the RIPE NCC understands that it will have to contact the Legacy Resource Holders that have had their Legacy Internet Resources registered under the umbrella of an LIR, either with or without a signed statement, to offer them the contractual options of the accepted proposal. The RIPE NCC will consider any requests submitted since 1992 and all statements as never having been submitted. insert: </p>

insert: <p>

insert: <b> insert: <br />
insert: </b>
insert: </p>

insert: <p>

insert: <b> Resource Certification insert: </b> insert: </p>

insert: <p>

The RIPE NCC would like to highlight that if the community decides that this proposal should allow for the certification of Legacy Internet Resources, the RIPE NCC will have to create a certification system specific to these resources. This is because of a previous decision by the RIPE NCC Executive Board to limit certification to Provider Aggregatable (PA) address space. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

D. Guidance Requested From the RIPE Community insert: </h3>

insert: <p>

The RIPE NCC is requesting guidance from the RIPE Community on the following points: insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Identifying the Legitimate Holder of a Legacy Internet Resource insert: </b> insert: </p>

insert: <p>

Background: insert: </p>

insert: <p>

Some Legacy Internet Resources were distributed by InterNIC to registries such as academic institutions and National Research and Education Networks (NRENs) with the intention that they would be further distributed to other organisations. Consequently, these Legacy Internet Resource blocks may contain several layers of hierarchy. insert: <br />
  insert: </p>

insert: <p>

Problem: insert: </p>

insert: <p>

It is often not clear who the legitimate holder of these resources is. Also, there are cases where the organisation running the registry ceased to exist or ended its registry function. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

Guidance requested: insert: </p>

insert: <p>

The RIPE NCC would like the community to clarify who it should consider to be the legitimate holder of these Legacy Internet Resources: the registry that originally received these resources for further distribution, or the organisation that later received these resources? insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Transparency for Legacy Internet Resources insert: </b> insert: </p>

insert: <p>

Background: insert: </p>

insert: <p>

Objects in the RIPE Database representing legacy Internet Resources in use in the RIPE NCC Service Region have several "status:" attribute values such as NOT-SET, ASSIGNED, ALLOCATED, EARLY-REGISTRATION. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

Problem: insert: </p>

insert: <p>

This situation does not allow for a transparent and consistent overview, clearly indicating which resources are legacy. The RIPE NCC receives many inquiries from organisations requesting clarification. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

Potential solution for IP addresses insert: </p>

insert: <p>

In order to solve this issue, and to increase the level of transparency, consistency and clarity, if this proposal is accepted, the RIPE NCC proposes to change the "status:" attribute value of all INETNUM objects for legacy space to the status LEGACY. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

Potential solution for AS numbers insert: </p>

insert: <p>

AUT-NUM objects do not currently have a "status:" attribute. For the same reasons described above, if this policy proposal reaches consensus, the RIPE NCC proposes to introduce a mandatory "status:" attribute to the AUT-NUM object. This new attribute would take the value 'LEGACY' for all legacy AS numbers. For all other AS numbers, this value would either be set to 'ASSIGNED' or 'OTHER'. The value 'ASSIGNED' would be for all AS number resources assigned by the RIPE NCC. The value 'OTHER' would be for copies of AS number resources assigned by other RIRs that have been added to the RIPE Database for routing purposes. insert: </p>

insert: <p>

The RIPE NCC would like the community to consider this as one possible solution for the issues raised, along with any other options, and advise the RIPE NCC on the best way forward. insert: </p>

insert: <p>

The impact on the RIPE NCC to implement the above points is considered as low impact. insert: </p>

insert: <p>

  insert: </p>

insert: <p>

insert: <b> Registration Services Operational Impact insert: </b> insert: </p>

insert: <p>

The number of legacy Internet Resources in the RIPE Registry is approximately 4200 IP blocks and 740 AS numbers. The Registration Services department will be able to assess the impact on its operations once it has received feedback on the points that need further clarification. insert: </p>

insert: <h2>

Abstract insert: </h2>

insert: <p>

This proposed framework establishes the principles to be applied by the RIPE community in offering and implementing registry services for legacy Internet resource holders. The importance of maintaining accurate records in the RIPE database is recognised as the NCC's principal task.  The community of legacy Internet resource holders is defined. Some rights of members of this community are described, as are the principles governing the manner in which the RIPE NCC should engage with and provide services to this community. insert: </p>

insert: <h2>

Content insert: </h2>

insert: <p>

1.0  insert: <a class="anchor-link" href="#introduction" target="_self" title=""> Introduction insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

1.1  insert: <a class="anchor-link" href="#definitions" target="_self" title=""> Definitions insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

1.2  insert: <a class="anchor-link" href="#scope" target="_self" title=""> Scope insert: </a> insert: </p>

insert: <p>

2.0  insert: <a class="anchor-link" href="#relationship" target="_self" title=""> Relationship between Legacy Internet Resource Holder and RIPE NC insert: </a> C insert: </p>

insert: <p style="padding-left: 30px; ">

2.1  insert: <a class="anchor-link" href="#legacy" target="_self" title=""> Legacy Internet Resource Holder is already a RIPE NCC Member insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

2.2  insert: <a class="anchor-link" href="#become" target="_self" title=""> Option become a RIPE NCC Member insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

2.3  insert: <a class="anchor-link" href="#engage" target="_self" title=""> Option to engage via sponsoring LIR insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

2.4  insert: <a class="anchor-link" href="#directly" target="_self" title=""> Option to engage directly with the RIPE NCC insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

2.5  insert: <a class="anchor-link" href="#obstacles" target="_self" title=""> When there are obstacles for 2.1/2.2/2.3/2.4 insert: </a> insert: </p>

insert: <p style="padding-left: 30px; ">

2.6  insert: <a class="anchor-link" href="#no_relationship" target="_self" title=""> No relationship insert: </a> insert: </p>

insert: <p>

3.0  insert: <a class="anchor-link" href="#contractual" target="_self" title=""> Contractual requirements insert: </a> insert: </p>

insert: <p>

4.0  insert: <a class="anchor-link" href="#services" target="_self" title=""> Services to be offered and provided insert: </a> insert: </p>

insert: <p>

5.0  insert: <a class="anchor-link" href="#arbitration" target="_self" title=""> Arbitration in case of conflict insert: </a> insert: </p>

insert: <p>

6.0  insert: <a class="anchor-link" href="#attribution" target="_self" title=""> Attribution insert: </a> insert: </p>

insert: <p>

  insert: </p>

insert: <h2>

insert: <a name="introduction"> insert: </a> 1.0  Introduction insert: </h2>

insert: <p>

Internet resources obtained prior to or otherwise outside the current hierarchical Internet Registry System (involving the RIPE NCC or any of the other Regional Internet Registries) are considered legacy resources. The RIPE NCC maintains and publishes registry data for resources held by its members and by legacy resource holders located in the RIPE NCC service area. It strives to maintain the accuracy of these data.  The RIPE NCC also provides reverse DNS delegation and a routing registry for IP address and Autonomous System Numbers, both of which include legacy resources. insert: </p>

insert: <p>

Historically, legacy resource holdings have been kept outside any insert: <b> insert: </b> formal relationship between their holders and the RIPE NCC, even in insert: <b> insert: </b> cases where such a relationship covers other resources held by the insert: <b> insert: </b> same holder. To improve the accuracy and trustworthiness of the insert: <b> insert: </b> registry data the RIPE NCC and a number of legacy resource holders insert: <b> insert: </b> have indicated that a formal relationship is desirable. insert: </p>

insert: <p>

Some of the legacy holders are also interested in a more formal relationship which would give clarity regarding services and allow them to participate in the RIPE NCC's cost-sharing model. insert: </p>

insert: <p>

This framework defines the basis for rigorous maintenance of registration data and for delivery of registry services to legacy Internet resource holders in the RIPE NCC service region. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <a name="definitions"> insert: </a> 1.1 Definitions insert: </h3>

insert: <p class=" ">

The following definitions apply in this policy and are of particular importance to the understanding of the goals described in this document. insert: </p>

insert: <p class=" ">

  insert: </p>

insert: <p>

insert: <b> Internet Resource: insert: </b> An IP address block or Autonomous System number. insert: </p>

insert: <p>

insert: <b> Legacy Internet Resource: insert: </b> Any Internet Resource obtained prior to or otherwise outside the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries. insert: </p>

insert: <p>

insert: <b> Legacy Internet Resource Holder: insert: </b> The holder of a Legacy Internet Resource. Either by receiving insert: <b> insert: </b> these resources directly or by receiving (part of) Legacy Internet insert: <b> insert: </b> Resources from a Legacy Internet Resource Holder. insert: </p>

insert: <p>

insert: <b> Registry Services: insert: </b> Services provided by the RIPE NCC in its capacity as a Regional insert: <b> insert: </b> Internet Registry, including the following and such additional insert: <b> insert: </b> services as may be identified from time to time as registry services: insert: </p>

insert: <ul>
    insert: <li>
  • Maintenance of data relating to Internet Resources by the NCC in their Internet Resource registry; insert: </li>
  • insert: <li>
  • Access to these data for update by or on behalf of the respective holder; insert: </li>
  • insert: <li>
  • Public availability of registration data; insert: </li>
  • insert: <li>
  • Certification of these data; and insert: </li>
  • insert: <li>
  • Delegation of reverse DNS to the registered DNS servers. insert: </li>
  • insert: </ul>
insert: <p>

insert: <b> Registry Service Element: insert: </b> In practice, any Legacy Resource Holder actually avails of a subset of the Registry Services mentioned above.  Where it is necessary to distinguish between the entire class of Registry Services and the specific Registry Services actually provided in a particular case, the latter are described as Registry Service insert: <b> insert: </b> Elements. insert: </p>

insert: <p>

insert: <b> insert: <br />
insert: </b>
insert: </p>

insert: <h3>

insert: <b> insert: <a name="scope"> insert: </a> 1.2 Scope insert: </b> insert: </h3>

insert: <p>

The framework described in this document applies to the provision of Registry Services by the RIPE NCC in respect of Legacy Internet Resources. Any other services offered by the RIPE NCC (whether different in nature, or relating to other kinds of resources) are out of scope for this policy. insert: </p>

insert: <p>

This scope of this policy does not include the resolution of any dispute arising as to the right to use a particular Legacy Internet Resource. insert: </p>

insert: <p>

Although specification of charges made by the RIPE NCC is also out of scope here, the appropriate kind of charge corresponding to a specific set of circumstances is identified where this seems useful for clarity. insert: </p>

insert: <p>

  insert: </p>

insert: <h2>

insert: <a name="relationship"> insert: </a> 2.0 Relationship between Legacy Internet Resource Holder and RIPE NCC insert: </h2>

insert: <p>

A direct or indirect contractual relationship between a Legacy Internet Resource Holder and the RIPE NCC provides contractual certainty to both parties regarding services, rights, and responsibilities.  Such a relationship also provides for payment of appropriate fees for services provided by the RIPE NCC. Different methods for establishing such a relationship are described below in sections 2.1, 2.2, 2.3, and 2.4. insert: </p>

insert: <p>

In exceptional cases where the Legacy Resource Holder wishes to engage with the RIPE NCC but none of the methods just mentioned is feasible, section 2.5 will apply. insert: </p>

insert: <p>

Section 2.6 below applies in all other cases. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <a name="legacy"> insert: </a> 2.1 Legacy Internet Resource Holder is already a RIPE NCC member insert: </h3>

insert: <p>

If the Legacy Internet Resource Holder is already a RIPE NCC member then there is already a contractual relationship between the RIPE NCC and the Resource Holder, who may extend the existing contract by registering the Legacy Internet Resources involved subject to the conditions defined in section 3 below. insert: </p>

insert: <p>

In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being in force. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <a name="become"> insert: </a> 2.2 Option to become a RIPE NCC member insert: </h3>

insert: <p>

A Legacy Internet Resource Holder who is not already a RIPE NCC member may opt to become a member by establishing a membership contract under which the Legacy Internet Resources involved will then be registered subject to the conditions defined in section 3 below. insert: </p>

insert: <p>

In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being in force. insert: </p>

insert: <p>

insert: <b>   insert: </b> insert: </p>

insert: <h3>

insert: <a name="engage"> insert: </a> 2.3 Option to engage via sponsoring LIR insert: </h3>

insert: <p>

A Legacy Internet Resource Holder who either is not already a RIPE NCC member or, being a member, does not wish to extend the membership contract as provided in section 2.1 above may opt to enter into a contract with a RIPE NCC member who is willing to act as a Sponsoring LIR for the purposes of registering the Legacy Resources involved, subject to the conditions defined in section 3 below, and subject to approval by the RIPE NCC of the form of contract between the Resource Holder and the Sponsoring LIR. insert: </p>

insert: <p>

In this case, the Sponsoring LIR may require the payment of charges according to the terms of the contract agreed with the Legacy Resource Holder. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <a name="directly"> insert: </a> 2.4 Option to engage directly with the RIPE NCC insert: </h3>

insert: <p>

A Legacy Internet Resource Holder whose circumstances match those described in section 2.3 above, but cannot find a Sponsoring LIR with which a mutually satisfactory contract of the kind mentioned in that section, may opt to enter a non-member service contract with the RIPE NCC for the purposes of registering the Legacy Resources involved, subject to the conditions defined in Section 3 below. insert: </p>

insert: <p>

In this case, the RIPE NCC may require the payment of reasonable charges according to the terms of the non-member service contract. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <a name="obstacles"> insert: </a> 2.5 When there are obstacles for 2.1/2.2/2.3/2.4 insert: </h3>

insert: <p>

Due to specific enduring or temporary circumstances which are recognised by the RIPE NCC as being outside the resource holder's control, a legacy resource holder may be unable to enter into a relationship of any of the kinds described above (2.1, 2.2, 2.3, 2.4).  In such a case, the RIPE NCC will offer and provide registry services as if a contractual relationship of one of the kinds described above had been established, and shall do so for as long as the circumstances continue which constitute an obstruction to the establishment of a contract.  insert: </p>

insert: <p>

However, notwithstanding the preceding paragraph, the RIPE NCC may refuse to provide any specific registry service for which particular technical requirements apply, which the Resource Holder is unable to meet. insert: </p>

insert: <p>

  insert: </p>

insert: <h3>

insert: <a name="no_relationship"> insert: </a> 2.6 No relationship insert: </h3>

insert: <p class=" ">

In cases where the current holder of Legacy Internet Resources cannot be contacted, does not reply to contact from the RIPE NCC or is unknown,  there is no formal relationship between the holder and the RIPE NCC. insert: </p>

insert: <p>

In such a case, the RIPE NCC insert: </p>

insert: <ul>
    insert: <li>
  • will continue to provide any registry service element already provided in support of each Legacy Internet Resource involved; insert: </li>
  • insert: <li>
  • will have no obligation to begin to provide any registry service element not already provided in support of a particular Legacy  Internet Resource, even in case the service element is provided in  support of any other Legacy Internet Resource held by the same or another Resource Holder; insert: </li>
  • insert: <li>
  • and may update the related entries in the RIPE Database from time to time to correspond to the current actual situation. insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <h2>

insert: <a name="contractual"> insert: </a> 3.0 Contractual requirements insert: </h2>

insert: <p>

The service agreement covering registration of a legacy Internet resource between the corresponding Resource Holder and either the Sponsoring LIR or the RIPE NCC must include insert: </p>

insert: <p>

 - identification of each resource covered by the service agreement; insert: </p>

insert: <p>

  - specification of the service or services offered in respect of each resource identified; insert: </p>

insert: <p>

 - a statement of the responsibility of the resource holder to maintain accurate data in the registry in respect of each resource identified; insert: </p>

insert: <p>

- acknowledgement that the terms and conditions under which the resources were originally granted are outside the scope of, and unchanged by, the service agreement. insert: </p>

insert: <p>

  insert: </p>

insert: <h2>

insert: <a name="services"> insert: </a> 4.0 Services to be offered and provided insert: </h2>

insert: <p>

The RIPE NCC will offer and provide services in respect of a given Legacy Internet Resource corresponding to the relationship established with the holder of that resource. insert: </p>

insert: <p>

In the case of any of the forms of relationship described in sections 2.1, 2.2, or 2.3 above, this policy shall not exclude any service from being offered and/or provided in respect of a Legacy Internet Resource registered under the terms of the corresponding direct or indirect contractual agreement relationship with the RIPE NCC. insert: </p>

insert: <p>

In the case of any of the forms of relationship described in sections 2.1, 2.2, 2.3, or 2.4 above, the RIPE NCC shall offer Registry Services as defined in section 1.1 above in respect of each Legacy Internet Resource involved and as requested by the corresponding Resource Holder. insert: </p>

insert: <p>

In case the situation corresponds to section 2.6 above, the RIPE NCC shall maintain each Registry Service already provided in respect of any corresponding Legacy Internet Resource. insert: </p>

insert: <p>

insert: <b> insert: <br />
insert: </b>
insert: </p>

insert: <h2>

insert: <a name="arbitration"> insert: </a> 5.0 Arbitration in case of conflict insert: </h2>

insert: <p>

In case of conflict between a Legacy Internet Resource Holder and the RIPE NCC about any matter within the scope of this policy, the RIPE NCC Conflict Arbitration Procedure is to be applied. insert: </p>

insert: <p>

insert: <b> insert: <br />
insert: </b>
insert: </p>

insert: <h2>

insert: <a name="attribution"> insert: </a> 6.0  Attribution insert: </h2>

insert: <p>

This document is developed by the RIPE community. insert: </p>

insert: <p>

The following people actively contributed by making proposals through the RIPE Policy Development Process: insert: </p>

insert: <p>

Niall O’Reilly, Bernard Tuy, Dave Wilson, Sander Steffann, Havard Eidnes, Hank Nussbacher, Carlos Friacas, Randy Bush insert: </p>

insert: <p>

  insert: </p>

RIPE NCC Services to Legacy Internet Resource Holders
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