[rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 - Internet Number Resources Review by AFRINIC"

[chenghn at chinaccsi.com]

Dear Co-chairs and community,

After carefully reading through the arguments put forward, I oppose this policy.
As I cannot see any positive outcome from the policy proposal for any
organizations that are members of AFRINIC.

It places AFRINIC ltd in dangerous legal grounds, it contradicts the
recently approved transfer policy and will cost money and time for all
involved parties.

As I cannot see any benefit but only negative impact I would like to
have my opposition to this policy recorded.

As a representative from a multi-continental organization having
business across all the globe, I cannot support a policy that may
affect network operators and an RIR in a negative way.

We strive to always operate under the regulations and policies set in
place, across all the RIRs as should all LIRs involved in their
various regions, we cooperate with the RIRs upon request for more
information.

But this policy leaving things for "better use" to be judged by the
AFRINIC Ltd is too subjective and cannot be fulfilled.

Then comes the arbitration process.
Who will be the arbiters?
How will they be selected?
Who will approve them ultimately, AFRINIC or the LIR being Audited?
What information will be provided to the Arbiters?

We understand that as part of an Audit, business critical information
will need to be shared with AFRINIC Ltd, we cannot accept to further
share that information with third parties selected from the community,
this would be a breach of confidentiality and involve sharing company
sensitive information such as customer lists and current network
strategies with potential competitors.

AFRINIC Ltd cannot share confidential information provided by its LIR
to third parties.

What will AFRINIC do when LIR take them to court and makes claims for damages?
The LIRs may very well decide to take AFRINIC to court in their own
country, AFRINIC will then need to defend themselves in Cameroon or
Nigeria, all this will cost a lot of money time and resources from
AFRINIC Ltd, which we will have to pay for.

This makes the policy having negative impact not only on the ones
being reviewed, but on the entire membership as we will all pay for
these reviews consequences.

Based on all the above, I again have to state that I formally oppose
this policy proposal in its current form.

Best Regards

Paul Cheng


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