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[rpd] Assisted Registry Checks

Caleb Olumuyiwa Ogundele muyiwacaleb at gmail.com
Tue Jun 25 05:13:54 UTC 2019


See comments inline

On Mon, Jun 24, 2019 at 10:21 PM JORDI PALET MARTINEZ via RPD <
rpd at afrinic.net> wrote:

> Hi Dewole,
>
> This is actually a good idea, and if I recall correctly, in the case of
> RIPE NCC, this was designed by the staff itself, looking for an objetive
> and fair process, and avoiding "flase claims" about possible competitors.
>
CO: This then supports an earlier argument that this is an operational
thing and does not need community approval.

>
> https://www.ripe.net/publications/docs/ripe-694
>
> You can see that this doesn't have the "random" bit of the review policy
> proposal, and still allows any member that has suspicius information about
> another member to tell the staff.
>

 CO: In this case, the same document you share allows for appeal and
dispute resolution in section 4 as seen below:

If the Resource Holder does not agree with the outcome of the performed
audit, they can apply for the initiation of the RIPE NCC Conflict
Arbitration Procedure <http://www.ripe.net/publications/docs/arbitration>.


>
> The staff will then review that information, but the main difference is
> that if they feel the information is wrong, they aren't mandated to start a
> complete audit.
>
> Regards,
> Jordi
> @jordipalet
>
>
>
> El 24/6/19 22:45, "Dewole Ajao" <dewole at forum.org.ng> escribió:
>
>     [was Re: [rpd] Proposal Update received: Internet Number Resources
>     Review by AFRINIC]
>
>     With the type of audit/review being discussed, the costs may vary
>     significantly from member to member - whether AFRINIC-side or
> Member-side.
>
>     I have however in the past mentioned that RIPE NCC has something
> simple
>     and time-efficient called Assisted Registry Checks and if I remember
>     correctly, they aim to check records for every member once in two
> years.
>     While we await the audit/review/recovery policy, it would be nice to
> see
>     AFRINIC start to implement basic checks (even before a member comes
> for
>     a repeat allocation).
>
>     See
>
> https://www.ripe.net/manage-ips-and-asns/resource-management/assisted-registry-check
>
>
>     These are simple checks to ensure registry accuracy and I see no
> reason
>     why anyone would try to discourage AFRINIC from checking the accuracy
> of
>     its records with the assistance of members.
>
>     This first step we can all agree on and staff can implement almost
>     immediately (in addition to the work they are already doing when
> members
>     come to them with issues arising from our lame-delegations and
>     no-reverse-unless-assigned policies).
>
>     Regards,
>
>     Dewole.
>
>
>     On 6/24/2019 7:20 PM, JORDI PALET MARTINEZ via RPD wrote:
>     > Hi Ish,
>     >
>     > I understand that, but my point is that there are two sides of the
> cost. And both should be considered:
>     >
>     > a) The cost for Afrinic (lets talk about average) for each review to
> an ISP.
>     >
>     > b) The cost for each member being reviewed (again we can get
> examples to calculate an average).
>     >
>     > Regards,
>     > Jordi
>     > @jordipalet
>     >
>     >
>     >
>     > El 24/6/19 20:00, "Ish Sookun" <ish.sookun at lasentinelle.mu>
> escribió:
>     >
>     >      I only requested an indicative value. I didn't ask to consider
> all
>     >      possibilities (e.g litigation, big or small ISP etc). The idea
> is to
>     >      obtain an approximate cost figure to evaluate whether the mere
>     >      implementation of this policy brings a financial burden on
> AfriNIC.
>     >
>     >      Regards,
>     >
>     >      Ish Sookun
>     >
>     >      On 6/24/19 7:31 PM, JORDI PALET MARTINEZ via RPD wrote:
>     >      > I think there is one more cost to be considered here as well.
>     >      >
>     >      >
>     >      >
>     >      > Each time an ISP gets the audit, it will need to dedicate
> staff for that.
>     >      >
>     >      >
>     >      >
>     >      > It is dificult to calculate “how much” that means, as it may
> depend on
>     >      > many factors, such as how big is the ISP, how many resources
> they have,
>     >      > how many customers from different types (business,
> residential), what
>     >      > provisioning system they have, IPAM if any, level of
> “automation” and
>     >      > “inventory” of the network, etc.
>     >      >
>     >      >
>     >      >
>     >      > May be it is a good exersice for some of you to calculate
> (rought idea),
>     >      > how much staff/resources and how many weeks, this will take
> to you, if
>     >      > the policy it is implemented?
>     >      >
>     >      >
>     >      >
>     >      > A few examples, could help the community to take a decision.
>     >      >
>     >      >
>     >      >
>     >      > Regards,
>     >      >
>     >      > Jordi
>     >      >
>     >      > @jordipalet
>     >      >
>     >      >
>     >      >
>     >      >
>     >      >
>     >      >
>     >      >
>     >      > El 24/6/19 17:25, "Timothy Ola Akinfenwa" <
> akin.akinfenwa at uniosun.edu.ng
>     >      > <mailto:akin.akinfenwa at uniosun.edu.ng>> escribió:
>     >      >
>     >      >
>     >      >
>     >      > Hello Andrew,
>     >      >
>     >      > While I also agree that Staff provide information on the
> likely
>     >      > financial implication for the audit, I don't understand why
> there should
>     >      > be a separate allocation for litigation.
>     >      >
>     >      >
>     >      >
>     >      > Is it wise for an organisation to budget funds for likely
> court cases
>     >      > when instead they should strive to prevent one in the first
> place?
>     >      >
>     >      >
>     >      >
>     >      > For me, I think it is critical to ensure that Staff actions
> on any audit
>     >      > review does not amount to litigation. And this may be
> captured as a
>     >      > suggestion in the policy as well, if necessary.
>     >      >
>     >      >
>     >      >
>     >      > Best!
>     >      >
>     >      > Sent from my OnePlus mobile device! </>$aa;
>     >      >
>     >      >
>     >      >
>     >      > On Mon, 24 Jun 2019, 3:53 PM Andrew Alston,
>     >      > <Andrew.Alston at liquidtelecom.com
>     >      > <mailto:Andrew.Alston at liquidtelecom.com>> wrote:
>     >      >
>     >      >     I would agree that these numbers would be useful - and
> must in
>     >      >     addition include contingent liability allocation for
> litigation that
>     >      >     could result due to implementation of this policy
>     >      >
>     >      >
>     >      >
>     >      >     Andrew
>     >      >
>     >      >
>     >      >
>     >      >     Liquid Telecommunications - Group Head Of IP Strategy
>     >      >
>     >      >
>  ------------------------------------------------------------------------
>     >      >
>     >      >     *From:*Ish Sookun <ish.sookun at lasentinelle.mu
>     >      >     <mailto:ish.sookun at lasentinelle.mu>>
>     >      >     *Sent:* Monday, June 24, 2019 5:39:19 PM
>     >      >     *To:* rpd at afrinic.net <mailto:rpd at afrinic.net>
>     >      >     *Subject:* Re: [rpd] Proposal Update received: Internet
> Number
>     >      >     Resources Review by AFRINIC
>     >      >
>     >      >
>     >      >
>     >      >     Dear PDWG Co-Chairs,
>     >      >
>     >      >     It was expressed during the last meeting that this policy
> will have
>     >      >     financial implications on AfriNIC due to costs associated
> to auditing.
>     >      >
>     >      >     Is it possible to obtain an approximate cost figure (from
> staff) that
>     >      >     such audits would entail?
>     >      >
>     >      >     Regards,
>     >      >
>     >      >     Ish Sookun
>     >      >
>     >      >     On 6/8/19 10:24 PM, Dewole Ajao wrote:
>     >      >     > Dear PDWG members,
>     >      >     >
>     >      >     > This is to inform you that authors of the policy
> proposal named
>     >      >     "Internet Number Resources Review by AFRINIC" have
> submitted an
>     >      >     updated version (Draft version 8) as included below. The
> URL will be
>     >      >     shared once published online.
>     >      >     >
>     >      >     > Please take some time to go through the proposal
> contents and
>     >      >     provide your feedback.
>     >      >     >
>     >      >     > Thank you.
>     >      >     > PDWG Co-Chairs
>     >      >     >
>     >      >     >
>     >      >     >
> ------------------------------------------------------------
>     >      >     >
>     >      >     > ------------------- Begin
>     >      >     >
>     >      >
>  ---------------------------------------------------------------------------------
>     >      >     >
>     >      >     >     Name : Internet Number Resources Review by AFRINIC
> (Draft 8)
>     >      >     >     Ref. Name: AFPUB-2016-GEN-001-DRAFT08
>     >      >     >     Status: Under Discussion
>     >      >     >     Date: 7 June 2019
>     >      >     >
>     >      >     > Authors:
>     >      >     >         (a) Amelina A. A. Arnaud | <
> arnaud.amelina at togorer.tg
>     >      >     <mailto:arnaud.amelina at togorer.tg>
>     >      >     > <mailto:arnaud.amelina at togorer.tg
>     >      >     <mailto:arnaud.amelina at togorer.tg>>> | AUF/TogoRER
>     >      >     >         (b) Jean-Baptiste Millogo |<
> jean.millogo at orange.com
>     >      >     <mailto:jean.millogo at orange.com>
>     >      >     > <mailto:jean.millogo at orange.com
>     >      >     <mailto:jean.millogo at orange.com>>>| Orange Burkina
>     >      >     >         (c) Marcus ADOMEY  <madomey at ug.edu.gh
>     >      >     <mailto:madomey at ug.edu.gh>
>     >      >     > <mailto:madomey at ug.edu.gh <mailto:madomey at ug.edu.gh>>>
> |
>     >      >     University of Ghana
>     >      >     >
>     >      >     > 13.0 Summary of the Problem Being Addressed by this
> Policy Proposal
>     >      >     >
>     >      >     > As Internet Number resources are finite, their
> allocation is based on
>     >      >     > the operational needs of end-users and Internet
> Services Providers,
>     >      >     > while avoiding stockpiling in accordance with RFC7020,
> IPv4 Allocation
>     >      >     > Policy CPM 5.5, IPv6 Allocation and assignment policy
> CPM 6.5 and
>     >      >     Policy
>     >      >     > for Autonomous System Numbers (ASN) Management in the
> AFRINIC
>     >      >     region CPM
>     >      >     > 7.0.Section 4 of the Registration Service Agreement
> (RSA) provides the
>     >      >     > framework for investigations of the usage of allocated
> Internet Number
>     >      >     > resources, defines members’ obligation to cooperate and
> the
>     >      >     measures to
>     >      >     > be taken by AFRINIC in case of failure to comply. The
> lack of such
>     >      >     > investigation or regular control can lead to
> inefficient usage of the
>     >      >     > Internet Number resources, to stockpiling and other
> type of abuses.
>     >      >     >
>     >      >     > 13.0.1 Summary of How this Proposal Addresses the
> Problem
>     >      >     >
>     >      >     > In order to ensure efficient and appropriate use of
> resources, AFRINIC
>     >      >     > shall conduct regular reviews of resource utilisation
> held by its
>     >      >     > members. This would allow recovery of any type of
> resource, where
>     >      >     usage
>     >      >     > is not in compliance with the RSA. Those resources can
> be reallocated
>     >      >     > for better usage.
>     >      >     >
>     >      >     > 13.0.2 Proposal
>     >      >     >
>     >      >     > The policy proposal will modify the CPM as follows:
>     >      >     >
>     >      >     > Insert a section 13 to the CPM as follows:
>     >      >     >
>     >      >     > 13.0 Internet Number Resources Review
>     >      >     >
>     >      >     > Regular reviews of resource utilisation are conducted
> by AFRINIC to
>     >      >     > ensure efficient and appropriate usage of resources.
> This allows for
>     >      >     > recovery of any type of resource where usage is not in
> compliance with
>     >      >     > the RSA; to allow such resources to be reallocated for
> better usage.
>     >      >     >
>     >      >     > 13.1 The reviews shall be based on compliance with the
> terms
>     >      >     outlined in
>     >      >     > the RSA and Allocation/Assignment Policies.
>     >      >     >
>     >      >     > 13.2 The reviews cover all allocated/Assigned
> resources, but priority
>     >      >     > goes to IPv4 and ASN mappable to two-octet ASN.
>     >      >     >
>     >      >     > 13.3 Classes of review: Members to be reviewed shall be
> selected
>     >      >     > according to the following classes:
>     >      >     >
>     >      >     > 13.3.1 Random
>     >      >     >
>     >      >     > The member is chosen by AFRINIC at random between the
> members who has
>     >      >     > not been reviewed for any other reasons in  the
> preceding 24 months.
>     >      >     >
>     >      >     >
>     >      >     > 13.3.2 Selected
>     >      >     >
>     >      >     >  Member is selected because of an internal report or
> due to a lack of
>     >      >     > contact between the AFRINIC and the member.
>     >      >     >
>     >      >     > 13.3.3 Reported:
>     >      >     >
>     >      >     > Here, members are reviewed either because:
>     >      >     >
>     >      >     > A) They have requested the review themselves or
>     >      >     >
>     >      >     > B) There has been a community complaint made against
> them that
>     >      >     warrants
>     >      >     > investigation. Complaints shall be backed by evidence
> and AFRINIC
>     >      >     staff
>     >      >     > shall evaluate the facts as appropriate to conduct the
> review. However
>     >      >     > this review is not applicable to a member  with the
> same resources
>     >      >     > portfolio on which a full review has been completed in
> the
>     >      >     preceding 24
>     >      >     > months.
>     >      >     >
>     >      >     >  AFRINIC staff may, at its sole discretion, after
> having assessed the
>     >      >     > nature of the evidence found in the community
> complaint, require that
>     >      >     > such evidence be (i) submitted in the form of a sworn
> affidavit or
>     >      >     (ii)
>     >      >     > declared to be true before a Commissioner of Oath.
>     >      >     >
>     >      >     > 13.4 In case of non-compliance and if evidence has been
> established in
>     >      >     > accordance with:
>     >      >     >
>     >      >     > •    Breach of AFRINIC policies
>     >      >     > •    Breach of the provisions of the registration
> service agreement or
>     >      >     > other legal agreements between the organisation holding
> the
>     >      >     resource and
>     >      >     > AFRINIC.
>     >      >     >
>     >      >     > AFRNIC shall initiate the resource recovery process on
> the portion of
>     >      >     > addresses found to be noncompliant.
>     >      >     >
>     >      >     > A) AFRINIC shall attempt to contact the organisation
> and correct any
>     >      >     > discrepancy towards the RSA. Except in cases of
> fraudulent resource
>     >      >     > acquisition or  unlawful usage and abuse, the
> organization shall be
>     >      >     > given a minimum of six(6) months to effect the return
> of the
>     >      >     resources.
>     >      >     >
>     >      >     > If the organisation is cooperative and working in good
> faith to
>     >      >     > substantially restore compliance or has a valid need for
>     >      >     additional time
>     >      >     > to renumber out of the affected blocks, AFRINIC shall
> negotiate a
>     >      >     longer
>     >      >     > term.
>     >      >     >
>     >      >     > The acceptance level of compliance and duration of the
> longer term are
>     >      >     > at AFRINIC staff discretion.
>     >      >     >
>     >      >     > B) If the situation cannot be rectified and the member
> did not
>     >      >     transfer
>     >      >     > the resources to meet other AFRINIC-approved needs as
> per adopted
>     >      >     policies
>     >      >     >
>     >      >     >  AFRINIC shall publish the resources to be recovered
> for a period of
>     >      >     > three (3) months; during which the organisation may at
> any time, seek
>     >      >     > compliance or transfer the resources to other members
>     >      >     >
>     >      >     >  After this period, the resource shall be recovered and
> therefore the
>     >      >     > records of the previous holder of the recovered
> resource shall be
>     >      >     > updated in AFRINIC’s databases.
>     >      >     >
>     >      >     > C)  Any Internet Number Resources recovered under this
> policy may be
>     >      >     > assigned/allocated under existing Allocation and
> Assignment Policies.
>     >      >     >
>     >      >     > 13.5 Appeal procedure
>     >      >     >
>     >      >     > Reviewed members who are not satisfied have the right
> to appeal
>     >      >     against
>     >      >     > the results on the review within the four weeks
> following
>     >      >     communication
>     >      >     > of the results by AFRINIC. Appeals shall follow an
> arbitration process
>     >      >     > as provided for in the
>     >      >     > Code de Procedure Civile (Code of Civil Procedure) of
> the Republic of
>     >      >     > Mauritius. AFRINIC may, on request from an aggrieved
> party, suggest a
>     >      >     > pool of arbitrators who shall be knowledgeable
> volunteers from the
>     >      >     > community.
>     >      >     >
>     >      >     > 13.6 Compliance Report
>     >      >     >
>     >      >     > AFRINIC shall publish an annual meaningful report
> describing review
>     >      >     > activities, in accordance with all applicable laws and
> regulations.
>     >      >     >
>     >      >     > 13.7 Acknowledgements
>     >      >     >
>     >      >     > The authors thank Ms Wafa Dahmani Zaafouri (become
> Afrinic GC
>     >      >     Chair), Mr
>     >      >     > Serge ILUNGA (become Afrinic Board member)  and Mr
> Alain P. Aina for
>     >      >     > their  contributions  in the development of this Policy
> proposal.
>     >      >     >
>     >      >     > The authors also thank the community for the
> discussions and
>     >      >     contributions.
>     >      >     >
>     >      >     > 4.0 Revision History
>     >      >     >
>     >      >     > 18 May 2016
>     >      >     >   Version 1.0
>     >      >     > - First Draft AFPUB-2016-GEN-001-DRAFT01
>     >      >     > - Posted on RPD list
>     >      >     >
>     >      >     > 05 Aug 2016
>     >      >     >   Version 2.0
>     >      >     > - Second Draft AFPUB-2016-GEN-001-DRAFT02
>     >      >     > - Change on the policy’s name
>     >      >     > - Addition of the Acknowledgement section
>     >      >     > - Rephrasing of section 3.3.3
>     >      >     >
>     >      >     > 18 Nov 2016
>     >      >     > Version 3.0
>     >      >     > - Third Draft AFPUB-2016-GEN-001-DRAFT03
>     >      >     > - Update of section 3.3.3 from discussions on mailing
> list
>     >      >     > - Update of section 3.7 (Acknowledgements) to thank the
> community for
>     >      >     > discussions and contributions
>     >      >     >
>     >      >     > 11 Apr 2017
>     >      >     > Version 4.0
>     >      >     > - Fourth Draft AFPUB-2016-GEN-001-DRAFT04
>     >      >     > - Update and Rephrasing of section 3.4
>     >      >     > - Update and Rephrasing of section 3.5
>     >      >     > - Update and Rephrasing of section 3.6
>     >      >     >
>     >      >     > 21 Oct. 2107
>     >      >     > Version 5.0
>     >      >     > - Fifth Draft AFPUB-2016-GEN-001-DRAFT05
>     >      >     > - Adding the paragraph C to 13.3.3. according to the
> legal counsel
>     >      >     > proposition
>     >      >     > - Rephrasing the paragraph 13.5 to comply with staff
> and legal
>     >      >     assessment
>     >      >     > - Rephrasing the paragraph 13.6 to comply with staff
> assessment and
>     >      >     > avoid any ambiguity
>     >      >     > - Changing the co-authors list
>     >      >     > - Updating the Acknowledgement session
>     >      >     > - Amending 13.4 (B) to  reflect the Transfer policies
>     >      >     >
>     >      >     > 06 Apr. 2018
>     >      >     > Version 6.0
>     >      >     > - Sixth Draft AFPUB-2016-GEN-001-DRAFT06
>     >      >     > - Removing categorisation between membership in random
> class
>     >      >     section 13.3.1
>     >      >     >
>     >      >     > 06 Apr. 2019
>     >      >     > Version 07
>     >      >     > - Seventh Draft AFPUB-2016-GEN-001-DRAFT07
>     >      >     > - Modifying section 13.4 Paragraph A) to clarify the
> resources
>     >      >     recovery
>     >      >     > process: set conditions  under which a member could be
> given
>     >      >     longer term
>     >      >     >  to effect the return of  affected resources.
>     >      >     >
>     >      >     > 29 may. 2019
>     >      >     > Version 08
>     >      >     > -  Eighth Draft AFPUB-2016-GEN-001-DRAFT08
>     >      >     > -  Section 13.3.1 changes to  : "..The member is chosen
> by AFRINIC at
>     >      >     > random between the members who has not been reviewed
> for any other
>     >      >     > reasons in  the preceding 24 months."
>     >      >     > -  Section  13.4  last paragraph changes to : "AFRINIC
> shall initiate
>     >      >     > ... on the portion of addresses found to be
> noncompliant."
>     >      >     > -   Section 13.5 changes to  “Reviewed members who are
> not satisfied
>     >      >     > have the right to appeal against the results on the
> review within the
>     >      >     > four weeks following communication of the results by
> AFRINIC……..”
>     >      >     > -  Typos and grammatical errors fixed.
>     >      >     >
>     >      >
>  -------------------------------------------------------------------------------
>     >      >     > End
>     >      >     >
>     >      >
>  ---------------------------------------------------------------------------------
>     >      >     >
>     >      >     >
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>     > **********************************************
>     > IPv4 is over
>     > Are you ready for the new Internet ?
>     > http://www.theipv6company.com
>     > The IPv6 Company
>     >
>     > This electronic message contains information which may be privileged
> or confidential. The information is intended to be for the exclusive use of
> the individual(s) named above and further non-explicilty authorized
> disclosure, copying, distribution or use of the contents of this
> information, even if partially, including attached files, is strictly
> prohibited and will be considered a criminal offense. If you are not the
> intended recipient be aware that any disclosure, copying, distribution or
> use of the contents of this information, even if partially, including
> attached files, is strictly prohibited, will be considered a criminal
> offense, so you must reply to the original sender to inform about this
> communication and delete it.
>     >
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>
>     _______________________________________________
>     RPD mailing list
>     RPD at afrinic.net
>     https://lists.afrinic.net/mailman/listinfo/rpd
>
>
>
>
> **********************************************
> IPv4 is over
> Are you ready for the new Internet ?
> http://www.theipv6company.com
> The IPv6 Company
>
> This electronic message contains information which may be privileged or
> confidential. The information is intended to be for the exclusive use of
> the individual(s) named above and further non-explicilty authorized
> disclosure, copying, distribution or use of the contents of this
> information, even if partially, including attached files, is strictly
> prohibited and will be considered a criminal offense. If you are not the
> intended recipient be aware that any disclosure, copying, distribution or
> use of the contents of this information, even if partially, including
> attached files, is strictly prohibited, will be considered a criminal
> offense, so you must reply to the original sender to inform about this
> communication and delete it.
>
>
>
>
> _______________________________________________
> RPD mailing list
> RPD at afrinic.net
> https://lists.afrinic.net/mailman/listinfo/rpd
>


-- 
*Ogundele Olumuyiwa Caleb*
*muyiwacaleb at gmail.com <muyiwacaleb at gmail.com>*
*234 - 8077377378*
*234 - 07030777969*
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