[LACNIC/Politicas] Host Sailor, Ltd.

Carlos Afonso ca at cafonso.ca
Tue Aug 16 17:15:29 BRT 2016


Thanks, Sergio, for the useful clarifications.

And all the best in your efforts.

fraternal regards

--c.a.

On 16/08/2016 16:22, Sergio Rojas. . . wrote:
> Dear Carlos Afonso,
> 
> Thank you for your contact.
> 
> First question
> Reallocated status in the LACNIC whois refers to the IPv4 block that you
> are querying is part of a bigger block.   As you can see in the last
> part of the first section, you can find the upper block (inetnum-up: 
> 131.72.136/22). This block is the main block allocated to HostSailor.
> The information shown for the subnet 131.72.136/24 is a registry that
> HostSailor made in the LACNIC system to register this subnet under the
> same name (HostSailor). This option in the LACNIC system is available
> for members to register all statics allocations made to their customers,
> in compliance to the point  2.3.2.13 - Submission of Assignment
> Information (http://www.lacnic.net/en/web/lacnic/manual-2)
> 
> Second question
> In regarding to the query shown for the ASN60117, RIPE NCC has allocated
> this ASN to Hostsailor but the result does not show any information
> about IPv4 block allocated by LACNIC because each RIR maintains their
> own data base independently. Hostsailor has received Internet resources
> from both RIRs.
> 
> If you have any other question please feel free to contact us again.
> 
> Best regards,
> 
> Sergio Rojas. . .
> 
> El 16/08/16 a las 10:54, Carlos Afonso escribió:
>> Dear people,
>>
>> When reading the Washington Post today I got a Host Sailor ad
>> (attached), and this led me to check some details on them. I pasted
>> below some whois results. I know I am stepping on a lot of eggs here,
>> surrounded by people who are orders of magnitude better informed than I
>> am on these tricks of the trade, as it were. But just to try and help to
>> clarify I dare to post this.
>>
>> First, the whois on the IP number 131.72.136.7 pointed by
>> hostsailor.com. Two interesting details:
>>
>> - the IP block Status is listed as "reallocated" (this category should
>> be a NetType in the whois jargon). What does this mean in this case?
>>
>> - the listed phone number is in central Los Angeles, so they seem to
>> have a tech op in LA - so may be accountable to US laws somehow?
>>
>> Second, the whois on Host Sailor's AS60117, under RIPE, which includes,
>> among several blocks, the 131.72.136.0/22 supposedly belonging to the
>> LACNIC pool.
>>
>> I am not sure what to make of this. Does it look like the IP block was
>> transferred from LACNIC to RIPE, and this would explain the "reallocated
>> status" in the LACNIC whois response?
>>
>> fraternal regards
>>
>> --c.a.
>>
>> ==============================
>>
>> Whois response on IP number 131.72.136.7 (hostsailor.com)
>>
>> cafonso at piccolo:~$ whois 131.72.136.7
>>
>> #
>> # ARIN WHOIS data and services are subject to the Terms of Use
>> # available at: https://www.arin.net/whois_tou.html
>> #
>> # If you see inaccuracies in the results, please report at
>> # https://www.arin.net/public/whoisinaccuracy/index.xhtml
>> #
>>
>>
>> #
>> # The following results may also be obtained via:
>> #
>> https://whois.arin.net/rest/nets;q=131.72.136.7?showDetails=true&showARIN=false&showNonArinTopLevelNet=false&ext=netref2
>>
>> #
>>
>> NetRange:       131.72.0.0 - 131.72.255.255
>> CIDR:           131.72.0.0/16
>> NetName:        LACNIC-ERX-131-72-0-0
>> NetHandle:      NET-131-72-0-0-1
>> Parent:         NET131 (NET-131-0-0-0-0)
>> NetType:        Transferred to LACNIC
>> OriginAS:
>> Organization:   Latin American and Caribbean IP address Regional
>> Registry (LACNIC)
>> RegDate:        2010-11-03
>> Updated:        2010-11-17
>> Comment:        This IP address range is under LACNIC responsibility
>> Comment:        for further allocations to users in LACNIC region.
>> Comment:        Please see http://www.lacnic.net/ for further details,
>> Comment:        or check the WHOIS server located at
>> http://whois.lacnic.net
>> Ref:            https://whois.arin.net/rest/net/NET-131-72-0-0-1
>>
>> ResourceLink:  http://lacnic.net/cgi-bin/lacnic/whois
>> ResourceLink:  whois.lacnic.net
>>
>> OrgName:        Latin American and Caribbean IP address Regional Registry
>> OrgId:          LACNIC
>> Address:        Rambla Republica de Mexico 6125
>> City:           Montevideo
>> StateProv:
>> PostalCode:     11400
>> Country:        UY
>> RegDate:        2002-07-27
>> Updated:        2011-09-24
>> Ref:            https://whois.arin.net/rest/org/LACNIC
>>
>> ReferralServer:  whois://whois.lacnic.net
>> ResourceLink:  http://lacnic.net/cgi-bin/lacnic/whois
>>
>> OrgAbuseHandle: LACNIC-ARIN
>> OrgAbuseName:   LACNIC Whois Info
>> OrgAbusePhone:  999-999-9999
>> OrgAbuseEmail:  whois-contact at lacnic.net
>> OrgAbuseRef:    https://whois.arin.net/rest/poc/LACNIC-ARIN
>>
>> OrgTechHandle: LACNIC-ARIN
>> OrgTechName:   LACNIC Whois Info
>> OrgTechPhone:  999-999-9999
>> OrgTechEmail:  whois-contact at lacnic.net
>> OrgTechRef:    https://whois.arin.net/rest/poc/LACNIC-ARIN
>>
>> #
>> # ARIN WHOIS data and services are subject to the Terms of Use
>> # available at: https://www.arin.net/whois_tou.html
>> #
>> # If you see inaccuracies in the results, please report at
>> # https://www.arin.net/public/whoisinaccuracy/index.xhtml
>> #
>>
>> Found a referral to whois.lacnic.net.
>>
>> % Joint Whois - whois.lacnic.net
>> %  This server accepts single ASN, IPv4 or IPv6 queries
>>
>> % LACNIC resource: whois.lacnic.net
>>
>> % Copyright LACNIC lacnic.net
>> %  The data below is provided for information purposes
>> %  and to assist persons in obtaining information about or
>> %  related to AS and IP numbers registrations
>> %  By submitting a whois query, you agree to use this data
>> %  only for lawful purposes.
>> %  2016-08-16 10:08:50 (BRT -03:00)
>>
>> inetnum:     131.72.136/24
>> status:      reallocated
>> owner:       HostSailor
>> ownerid:     NL-HOST-LACNIC
>> responsible: Host Sailor Ltd.
>> address:     Databarn Amsterdam, ,
>> address:      - Amsterdam -
>> country:     NL
>> phone:       +1  2132344292 []
>> owner-c:     HOM16
>> tech-c:      HOT10
>> abuse-c:     HOA7
>> inetrev:     131.72.136/24
>> nserver:     NS1.NL.HOSTSAILOR.COM
>> nsstat:      20160815 AA
>> nslastaa:    20160815
>> nserver:     NS2.NL.HOSTSAILOR.COM
>> nsstat:      20160815 AA
>> nslastaa:    20160815
>> created:     20140826
>> changed:     20140826
>> inetnum-up:  131.72.136/22
>>
>> nic-hdl:     HOA7
>> person:      HostSailor Abuse
>> e-mail:      abuse at HOSTSAILOR.COM
>> address:     HDS Business Centre 3204, Jumeirah Lakes Towers, ,
>> address:     309096 - Dubai -
>> country:     AE
>> phone:       +1  2132344292 []
>> created:     20140815
>> changed:     20160307
>>
>> nic-hdl:     HOM16
>> person:      HostSailor Management
>> e-mail:      ripe at HOSTSAILOR.COM
>> address:     HDS Business Centre 3204, Jumeirah Lakes Towers, ,
>> address:     309096 - Dubai -
>> country:     AE
>> phone:       +1  2132344292 []
>> created:     20140815
>> changed:     20160307
>>
>> nic-hdl:     HOT10
>> person:      HostSailor Tech
>> e-mail:      tech at HOSTSAILOR.COM
>> address:     HDS Business Centre 3204, Jumeirah Lakes Towers, ,
>> address:     309096 - Dubai -
>> country:     AE
>> phone:       +1  2132344292 []
>> created:     20140815
>> changed:     20160307
>>
>> % whois.lacnic.net accepts only direct match queries.
>> % Types of queries are: POCs, ownerid, CIDR blocks, IP
>> % and AS numbers.
>>
>> ------------------------------------------
>>
>> Whois data pertaining to AS60117:
>>
>> aut-num:         AS60117
>> as-name:         HS
>> descr:           Host Sailor Ltd.
>> org:             ORG-HSL15-RIPE
>> import:          from AS43350 action pref=100; accept ANY
>> import:          from AS9009 action pref=100; accept ANY
>> export:          to AS43350 announce AS60117
>> export:          to AS9009 announce AS60117
>> admin-c:         AF11712-RIPE
>> tech-c:          AF11712-RIPE
>> remarks:         For information on "status:" attribute read
>> https://www.ripe.net/data-tools/db/faq/faq-status-values-legacy-resources
>> status:          ASSIGNED
>> notify:          ripe at hostsailor.com
>> mnt-by:          RIPE-NCC-END-MNT
>> mnt-by:          MNT-HS
>> created:         2014-05-13T09:43:21Z
>> last-modified:   2015-09-25T09:25:09Z
>> source:          RIPE
>>
>> organisation:    ORG-HSL15-RIPE
>> org-name:        Host Sailor Ltd.
>> org-type:        LIR
>> address:         HDS Business Centre 3204, Jumeirah Lakes Towers
>> address:         N/A
>> address:         Dubai
>> address:         UNITED ARAB EMIRATES
>> phone:           +12132344292
>> e-mail:          ripe at hostsailor.com
>> mnt-ref:         RIPE-NCC-HM-MNT
>> mnt-ref:         MNT-HS
>> mnt-by:          RIPE-NCC-HM-MNT
>> abuse-mailbox:   abuse at hostsailor.com
>> tech-c:          AF11712-RIPE
>> abuse-c:         HA3004-RIPE
>> created:         2014-12-30T11:58:01Z
>> last-modified:   2015-09-14T15:24:47Z
>> source:          RIPE
>>
>> person:          Alexander Freeman
>> address:         HDS Business Centre 3204
>> address:         Jumeirah Lakes Towers
>> address:         Dubai
>> address:         United Arab Emirates
>> phone:           +12132344292
>> nic-hdl:         AF11712-RIPE
>> mnt-by:          MNT-HS
>> abuse-mailbox:   abuse at hostsailor.com
>> created:         2014-06-30T16:22:26Z
>> last-modified:   2015-09-14T15:22:32Z
>> source:          RIPE
>>
>> This AS points to several IP blocks, among them:
>>
>> Netblock    Description    Num IPs
>> 131.72.136.0/22     HOSTSAILOR    1,024
>>
>>
>> On 15/08/2016 17:11, Carlos Vera wrote:
>>> Excelente response from LACNIC
>>>
>>> Carlos Vera
>>>
>>> Enviado desde mi smartphone BlackBerry 10.
>>>    Mensaje original
>>> De: Sergio Rojas. . .
>>> Enviado: lunes, 15 de agosto de 2016 14:55
>>> Para: politicas at lacnic.net
>>> Responder a: Lista para discusion de politicas de la comunidad de LACNIC
>>> Asunto: Re: [LACNIC/Politicas] Host Sailor, Ltd.
>>>
>>> Dear Mr. Guilmette,
>>>
>>> As we mentioned before, after your initial message we started our
>>> process approaching the organization HostSailor to commence an inquiry
>>> of the alleged use of the assigned resources outside of the LACNIC
>>> region. If the results of our investigation confirm the alleged out of
>>> region use, we would commence the revocation process of these resources,
>>> according to our policies.
>>>
>>> Ragarding what you comment about improving existing policies, everyone
>>> in the community can modify an existing policy or propose a new one.
>>> According to the Policy Development Process
>>> (http://www.lacnic.net/web/lacnic/proceso-de-desarrollo-de-politicas)
>>> new proposals are created by the community and then discussed in the
>>> policy list. Finally, the community is the one who reaches a consensus
>>> in order to approve policies. The process is open to all community
>>> members. Everyone can present a new policy proposal
>>> (https://politicas.lacnic.net/politicas/new). Last year LACNIC has
>>> implemented a new mechanism in order to provide assistance to any author
>>> who wants to present a new policy proposal; the policy shepherds. If you
>>> would like to contact a policy shepherd, please write to
>>> info-politicas at lacnic.net
>>>
>>> Thank you for the information you have provided. Let us know if we can
>>> help or give you more information about the Policy Development Process
>>> or any other process at LACNIC.
>>>
>>> Kind regards,
>>>
>>> Sergio Rojas. . .
>>>
>>>
>>> El 13/08/16 a las 20:51, Ronald F. Guilmette escribió:
>>>> Mr Rojas,
>>>>
>>>> In your latest response to me on this list, you suggested that I have
>>>> misused this mailing list to discuss issues that are unrelated to
>>>> LACNIC policy. I respectfully disagree, and I will make my case more
>>>> fully below.
>>>>
>>>> I believe that you and your fellow staff members of LACNIC have made
>>>> and are making serious errors in your interpretation and application
>>>> of the true intent and spirit of existing LACNIC policies, and that
>>>> these errors in the interpretation of existing LACNIC policies are
>>>> materially harming not only LACNIC members, but the entire Internet
>>>> community worldwide.
>>>>
>>>> If there is some better place to discuss the proper interpretation and
>>>> application of LACNIC policies and/or new policy proposals that would
>>>> correct these LACNIC staff misinterprerations of existing LACNIC
>>>> policies,
>>>> then by all means, please do tell me where that better place might be,
>>>> and then I will go and post there instead of here.
>>>>
>>>> Until then however, I wish to continue to present evidence here about
>>>> the absurd results of your misinterpretation of existing LACNIC policy,
>>>> results which apparently endorse and allow parties that have -zero-
>>>> actual footprint within the LACNIC region to hold onto sizable blocks
>>>> of IPv4 number resources.
>>>>
>>>> I respond in detail to your various points below.
>>>>
>>>> Before I do however, allow me to clarify *up front* that the real issue
>>>> I have attempted to raise here is *not* the possibility or probability
>>>> of either the customers of HostSailor or HostSailor itself enganging in
>>>> criminal acts. The real issue I have attempted to raise here is whether
>>>> or not HostSailor has effectively defrauded LACNIC itself out of two
>>>> valuable and precious /22 blocks. That is, quite obviously, the *only*
>>>> issue that LACNIC can do anything about, and it is an issue which, I
>>>> believe, LACNIC is morally, ethically, and legally obliged to do
>>>> something about, under a correct interpretation of existing LACNIC
>>>> policies.
>>>>
>>>> In message <78f4435d-8861-bb11-9fcf-58b59fac0070 at lacnic.net>, you
>>>> wrote:
>>>>
>>>>> According to LACNIC policy (1.11), The numbering resources under the
>>>>> stewardship of LACNIC must be distributed among organizations legally
>>>>> constituted within its service region and mainly serving networks and
>>>>> services operating in this region. External clients connected directly
>>>>> to main infrastructure located in the region are allowed.
>>>> That is, of course, an entirely appropriate LACNIC policy, as a general
>>>> matter. But how does (or how should) that general policy be applied in
>>>> the specific case of this organization calling itself HostSailor?
>>>>
>>>> As I noted in my prior message, simple traceroutes demonstrate
>>>> convincingly
>>>> that this company has -zero- infrastructure within the LACNIC
>>>> region. In
>>>> fact, I believe that the facts will show that it -never- had any
>>>> equipment
>>>> or infrastructure of any kind within the LACNIC region. Given that
>>>> fact,
>>>> will LACNIC now take back the 131.72.136/22 and 138.99.216/22 blocks,
>>>> since they are clearly -not- being used in accordance with LACNIC
>>>> policy?
>>>>
>>>> Doesn't LACNIC have legitimate members who actually *do* have actual
>>>> and
>>>> real infrastructure within the LACNIC region who desperately need more
>>>> IPv4 addresses, and who could make good and legitimate use of the two
>>>> /22 block in question for their actual infrastructure within the
>>>> region?
>>>>
>>>>> As mentioned in our previous response, HostSailor provided legal
>>>>> documentation demonstrating their legal presence in Belize, and
>>>>> presented a plan detailing how they will use the resources in the
>>>>> region, complying at that moment with the requirements established in
>>>>> the policies developed by our community.
>>>> I will try to be clear about this. It is my contention that
>>>> HostSailor's
>>>> creation of a Belizian corporation was an outright *fraud* and that
>>>> it was
>>>> done *only* for the purpose of obtaining some scarce and precious
>>>> LACNIC
>>>> IPv4 address space... which is exactly what the company has done.
>>>>
>>>> You only have to do a little research on the Belize mailing address
>>>> that
>>>> HostSailor has been using in conjunction with their two LACNIC /22
>>>> address blocks in order to understand what this address really is.
>>>> Here is the address:
>>>>
>>>> 16 Lauren Berges Crescent, Belama Phase-3 2, Belize City, BZ
>>>>
>>>> If you simply google for that address, as I have done, then you will
>>>> quickly learn that this address is used by SEVERAL shady companies,
>>>> including even one named Green Road Corporation which is named in a
>>>> current *criminal* complaint, filed by the U.S. Securities and Exchange
>>>> Comission against a number of parties relating to a massive stock fraud
>>>> scheme:
>>>>
>>>> https://www.sec.gov/litigation/complaints/2016/comp23471.pdf
>>>> (see page 2 for named defendant Green Road Corporation)
>>>>
>>>> To be entirely clear, I am *not* saying that HostSailor has any
>>>> specific
>>>> relationship to this Green Road Corporation that is currently the
>>>> subject
>>>> of a U.S. SEC criminal action, other than the fact that they both have
>>>> used the same mailing address... an apartment in Belize City... as
>>>> their
>>>> address for legal purposes, along with *several* other companies.
>>>>
>>>> It is actually not all that surprising that HostSailor and many other
>>>> companies (including the crininal stock manipulators of Green Road
>>>> Corporation) are all using the exact same Belize mailing address. I
>>>> have seen this type of thing many times before.
>>>>
>>>> The reason several companies give the exact same mailing address...
>>>> usually just a post office box, but in this case a small apartment in
>>>> Belize City... is because there is a company at that address which is
>>>> in the business of creating so-called "offshore" paper-only companies
>>>> for other parties. And in the case of HostSailor's alleged "16 Lauren
>>>> Berges Crescent" address it is simple to find that incorporation
>>>> company.
>>>> We only have to googling for the address to find it. Here is the
>>>> "offshore" incorporation company in question:
>>>>
>>>> https://www.belize-offshore.info/
>>>>
>>>> (Note that this company is not even run by a Belizian citizen. As the
>>>> WHOIS record for the domain shows, this incorporation company is itself
>>>> actually run by a Russian gentleman named Konstantin Titov, most
>>>> probably
>>>> from Moscow.)
>>>>
>>>> That fact that HostSailor created a fictitious paper-only company in
>>>> Belize only so that it could get its hands on some nice valuable
>>>> chunks of LACNIC IPv4 real estate should really not be all that
>>>> surprising to anyone given these additional known facts about
>>>> HostSailor,
>>>> which speak to the general character (or lack thereof) of the owner
>>>> of the company:
>>>>
>>>> (1) HostSailor has previously done the exact same thing also in the
>>>> "offshore" jurisdiction of the United Arab Emirates, where it
>>>> also created a secretive and untracable paper-only company that
>>>> also did not allow anyone to find out who the actual "beneficial
>>>> owners" of the company are. (This is a unique feature of both
>>>> Belize and UAE companies. They are both totally untracable and
>>>> anonymous, which explains why international criminals like them
>>>> so much.)
>>>>
>>>> (2) As TrendMicro, Brian Krebs, and myself have all now pointed out
>>>> in public postings, this company, HostSailor, is not exactly a
>>>> shining model of honesty and/or integrity. It has allowed various
>>>> hacker criminals to use its IP address space repeatedly and
>>>> continually since the company's formation, barely three years
>>>> ago. And in fact, the HostSailor was created by the same man
>>>> who had owned the norotious "bulletproof" hosting company called
>>>> Santrex, before it was effectively forced off the Internet in 2013.
>>>>
>>>> To be clear, I *do not* expect or ask that LACNIC respond in any way
>>>> to the
>>>> various criminal activities taking place within Hostsailor's
>>>> allocated IP
>>>> address space. That is the job of law enforcement. Everyone, including
>>>> myself, agrees on that. I have only tried to provide some background
>>>> information about Santrex/HostSailor so that you, Mr. Rojas, and
>>>> everyone
>>>> within the LACNIC community will fully appreciate that the owner of
>>>> this
>>>> company has no morality and no ethics. Now that everyone can see that,
>>>> it now should also be much easier for everyone to understand and
>>>> appreciate
>>>> that the owner of HostSailor certainly would not hesitate to use dirty
>>>> tricks, fraud, and paper-only companies as a means to fradulently
>>>> obtain
>>>> IPv4 blocks from LACNIC, even if he has no legitimate right to such
>>>> blocks,
>>>> at least under a *correct* interpretation of the well-established
>>>> LACNIC
>>>> rules and policies.
>>>>
>>>>> We appreciate the information you have provided about the
>>>>> utilization of
>>>>> these resources outside the Latin America and Caribbean region and we
>>>>> are going to further investigate the matter and follow our policies in
>>>>> that process.
>>>> Thank you Mr. Rojas. I am looking forward to the correct application of
>>>> the existing LACNIC policies in this case.
>>>>
>>>> I want to be clear however. The simplest way I can put this so that
>>>> everyone will immediately understand my point is for me to say, with
>>>> respect to the LACNIC policies, "There is a bug in your system."
>>>> HostSailor has now found this bug, and has exploited it for its own
>>>> sinister and corrupt ends.
>>>>
>>>> The "bug" in this case is just this: LACNIC has sometimes allocated
>>>> scarce IPv4 address space to fradulent "paper only" companies that have
>>>> been created, in particular, within the secretive and criminal-friendly
>>>> "offshore" jursidiction of Belize. It appears that LACNIC staff have
>>>> issued such allocations because doing so *seems* to be "required" by
>>>> the existing LACNIC policies which oblige LACNIC to give IP address
>>>> blocks to *any* company that appears to be "legally constituted"
>>>> anywhere
>>>> within the LACNIC region.
>>>>
>>>> However, as we see in this specific case (HostSailor) -and others-,
>>>> *any party* that actually resides *anywhere in the world* can simply
>>>> purchase
>>>> a "Belize" corporation, anonymously, and over the Internet, and that
>>>> party can then use that fiction of a company to obtain and/or maintain
>>>> allocations of scarce IPv4 address blocks from LACNIC. As indicated at
>>>> the URL given above, any party can do this for as little as $400 USD,
>>>> quickly, easily, inexpensively, and in a single afternoon.
>>>>
>>>> The fact that anybody, anywhere in the world can so easly defraud
>>>> LACNIC
>>>> out of valuable IPv4 address space is a "bug" in the LACNIC system, and
>>>> one that has been, and that *is being* exploited. That bug, that
>>>> loophole,
>>>> should be fixed, and immediately. It is unfair and unjust to deny IPv4
>>>> addresses to legitimate companies that really are within the LACNIC
>>>> region, even as other companies that are not really within the region
>>>> are allowed to obtain or... in the case of HostSailor... maintain
>>>> allocations which were obtained by means of simple and obvious fraud.
>>>>
>>>>> Regarding your allegations of illegal activities by HostSailor,
>>>>> even if
>>>>> they are effectively accurate, we do not have established any
>>>>> procedures, policy nor contractual right to proceed...
>>>> See above. Mr. Rojas, I agree with you completely. It is clearly not
>>>> the job of LACNIC to act as "The Internet Police", and LACNIC cannot
>>>> and should not be in the business of either investigating cybercrime
>>>> in general, or in reacting to it.
>>>>
>>>> However it is *not* cybercrime "in general" that caused me to write to
>>>> this mailing list. Rather, I have written to this mailinmg list in
>>>> order to report what appears to be a clear-cut case where LACNIC itself
>>>> has been defrauded, and to request that LACNIC now respond to that
>>>> fraud,
>>>> and take appropriate corrective action to reverse and nullify the
>>>> negative
>>>> effects of this fraud against LACNIC itself, as it can, should, and
>>>> must
>>>> do, in accordance with a correct and reasonable interpretation of
>>>> existing
>>>> LACNIC policies.
>>>>
>>>> As I understand it, existing LACNIC policies do not allow legal
>>>> entities
>>>> that have -zero- actual infrastructure within the region to either
>>>> obtain or maintain LACNIC-allocated number resources. I believe that
>>>> all available evidence will show that HostSailor has -zero- actual
>>>> infrastructure within the region. It has no servers, no routers, no
>>>> connections to other providers within the region, no offices, no desks,
>>>> no phones, no FAX machines, no offices, no secretaries, no technicians,
>>>> no employees, and no equipment or installations of any kind within the
>>>> LACNIC region. All it does have is a canceled check for $400 USD and
>>>> a thin piece of paper that says that the company maintains a "legal"
>>>> mailing address within a small apartment in Belize City... the exact
>>>> same apartment where *several* other fictitious companies... including
>>>> one currently being criminally prosecuted by the United States
>>>> Securities
>>>> and Exchange Commission... are also allegedly domiciled.
>>>>
>>>> Now that LACNIC has been informed about all of these irregularities
>>>> related to HostSailor, if LACNIC continues to allow this legal fiction
>>>> called HostSailor to maintain the IPv4 address allocations that it
>>>> obtained from LACNIC, then this will represent a travesty of justice
>>>> as well as representing LACNIC's willingness to look the other way,
>>>> even as LACNIC itself is being defrauded via a simple and obvious
>>>> "legal" scheme. I believe that all of the legitimate LACNIC members
>>>> deserve better, and I hope to see this unfortunate fraud being reversed
>>>> and corrected as soon as it is practical to do so.
>>>>
>>>> Again, I am *not* asking LACNIC to act in the capacity of law
>>>> enforcement.
>>>> That would be wrong. I am only asking LACNIC to do its job... to do
>>>> exactly
>>>> what it was formed to do, i.e. to act as a "good steward" of the number
>>>> resources which have been placed into its care. LACNIC will have failed
>>>> in that responsibility if it continues to allow itself to be defrauded
>>>> by this company, HostSailor, only because the company has found and
>>>> exploited a clever "legal" ruse to obtain IPv4 space that it would
>>>> otherwise not be at all entitled to.
>>>>
>>>>> As explained in the previous paragraph we are following our role the
>>>>> community has defined in the policies for the assignment of internet
>>>>> addresses,
>>>> I'm sorry, but I must disagree Mr. Rojas. If you indeed plan to contine
>>>> to allow HostSailor to enjoy the benefits of the two LACNIC /22 blocks
>>>> that it has obtained by means of its clever legalistic fraud, then in
>>>> that case you may perhaps use the excuse that you are following the
>>>> "letter" of the LACNIC policy (which requires LACNIC to give IP space
>>>> to any legal entity within the region) but you cannot with a straight
>>>> face say that you are following the "spirit" or the true intent of the
>>>> existing LACNIC policies. The spirit and intent of LACNIC policy is
>>>> clear: To serve the needs of the Internet community that is -actually-
>>>> located within the Latin American and Caribbean geographical area.
>>>>
>>>> HostSailor is -not- within the LACNIC region in any real sense.
>>>>
>>>> Despite the purchased and manufactured fiction of HostSailor's location
>>>> within Belize, all actual evidence relating to all of HostSailor's
>>>> actual assets and infrastructure indicate that it has no real presence
>>>> whatsoever within the LACNIC region, and never has had any. Thus, if
>>>> you and LACNIC are now going to claim... as you seem to be doing...
>>>> that HostSailor should be permitted to keep the two /22 blocks that
>>>> were given to it (under false pretenses) by LACNIC, only because it
>>>> has purchased one flimsey piece of paper that proves nothing, then
>>>> you are -not- in fact "following the role the community has defined
>>>> in the policies". Rather, you are, in effect, -defending- the
>>>> clever legal trickery that HostSailor has used to defraud LACNIC
>>>> and to obtain number resources... number resources which the clear
>>>> intent and spirit of the LACNIC policies would not permit it to have.
>>>>
>>>> Are you really going to defend the idea that LACNIC will give out /21
>>>> sized blocks to anyone who presents LACNIC with a single piece of
>>>> paper that anybody anywhere in the world can purchase in an afternoon
>>>> for a mere $400??
>>>>
>>>> If so, then I would like to propose a new LACNIC policy, on this
>>>> mailing
>>>> list, that would prohibit all LACNIC staff from allowing any legal
>>>> entity to either obtain or maintain LACNIC-allocated number resources
>>>> purely and only on the basis of legal fictions that are manufactured,
>>>> upon request, in particular within Belize or any other country within
>>>> the LACNIC region that allows companies to be formed in the total
>>>> absence of any information about the actual "beneficial ownership" of
>>>> these companies.
>>>>
>>>> (Note that this exact type of reform has already been accomplished
>>>> within
>>>> the financial sector, and it is nowadays much more difficult than it
>>>> was
>>>> in past years to launder money through places like the Cayman Islands,
>>>> the British Virgin Islands, and other such traditional corporate
>>>> secrecy
>>>> havens. If this sort of accountability and transparency can be achieved
>>>> within the sphere of financial transactions, there is no reason why
>>>> there
>>>> should not likewise exist some minimal amount of accountability and
>>>> transparency with respect to valuable IPv4 real estate.)
>>>>
>>>>> so we kindly request to keep this mailing list for the
>>>>> purposes it was established (update or propose a new one).
>>>> You are suggesting that I have been discussing matters here, on this
>>>> mailing list, that do not relate gto LACNIC policies. Once again, I
>>>> must respectfully disagree Mr. Rojas.
>>>>
>>>> What could possibly be more relevant to this exact mailing list than a
>>>> discussion of the correct interpretation of, and the correct
>>>> application
>>>> of existing LACNIC policies?
>>>>
>>>> Indeed, in the posting to which I am responding now, you defended the
>>>> LACNIC allocations that were made... and that still exist... to
>>>> HostSailor
>>>> on the basis of one possible interpretation of the existing LACNIC
>>>> policies relating to IPv4 block allocations. For all the reasons noted
>>>> above, I assert that any interpretation of LACNIC policies that allows
>>>> this crooked company... which doesn't have -any- assets within the
>>>> LACNIC
>>>> region...to keeep its current LACNIC allocations is just plain wrong.
>>>>
>>>> So you see, we -are- quite clearly debating serious LACNIC policy
>>>> questions. Isn't this the LACNIC "Policy" mailing list? If it is,
>>>> then I fail to see how or why this discussion is somehow off-topic for
>>>> this list.
>>>>
>>>>> Finally, the fact that the person who responds to your questions is
>>>>> listed at the bottom of an alphabetically ordered list, doesn't
>>>>> make me
>>>>> less authorized to answer you, if that is what you implied by your
>>>>> tone
>>>>> in your message. I'm in charge of analyzing IP requests in LACNIC and
>>>>> have the authority to answer you. I request you to communicate with
>>>>> respect to me or anyone in this list if you want to keep this
>>>>> dialogue.
>>>> Mr. Rojas, it is my sincere hope that we can both show respect for each
>>>> other. That goes both ways.
>>>>
>>>> I feel that you were too quick to be dismissive of the important issues
>>>> I have raised with respect to this case (HostSailor), and that you have
>>>> not treated either me or the issues I have raised here with any real
>>>> respect whatsoever.
>>>>
>>>> As I have noted at length above, there are, I think, clear reasons why
>>>> (a) HostSailor's LACNIC IPv4 allocations should be immediately revoked
>>>> and (b) that this can be done and indeed must be done under existing
>>>> LACNIC policy and that (c) if in fact LACNIC staff is asserting that
>>>> HostSailor is actually entitled, under current policy, to the LACNIC-
>>>> issued IPv4 block allocations that it currently has, then either LACNIC
>>>> staff is wrong, or the policy is wrong, or perhaps both.
>>>>
>>>> These are all substantive *Policy* issues, and yet you dismissed my
>>>> original posting as if I was just some schoolboy who had wandered by
>>>> mistake into the wrong classroom.
>>>>
>>>> In future, I will endeavor to strike a tone which is in all ways
>>>> utterly
>>>> respectful towards you and all other LACNIC staff. My hope is that you
>>>> will likewise and similarly accord me and the valid policy issues I
>>>> have
>>>> raised with appropriate respect.
>>>>
>>>>
>>>> Regards,
>>>> rfg
>>>> _______________________________________________
>>>> Politicas mailing list
>>>> Politicas at lacnic.net
>>>> https://mail.lacnic.net/mailman/listinfo/politicas
>>> _______________________________________________
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>>> _______________________________________________
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>>> https://mail.lacnic.net/mailman/listinfo/politicas
>>>
>>
>>
>> _______________________________________________
>> Politicas mailing list
>> Politicas at lacnic.net
>> https://mail.lacnic.net/mailman/listinfo/politicas
> 
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Carlos A. Afonso
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