Subject: RE: [Enum] Tier II roll out

From: "Christian Huitema" <[email-masked]>
Date: Tue, 20 Feb 2001 09:12:50 -0800

> In these 12 years, Tony's occasional, recent comments have 
> been the only 
> time that anyone has raised anti-trust concerns in working group 
> discussions.  Also within those 12 years, the IETF has not 
> been the subject 
> of a single lawsuit or investigation, for anti-trust or anything else.

Dave,

The reason for the absence of concern has been the strict avoidance of
any "business" decision. For example, when the IETF defines BGP, it
defines how two parties that have reached a peering agreement can encode
that agreement using bits in the protocol; however, the IETF never tries
to define who should peer with whom. That is, define the technology,
don't define the business practices.

The ENUM technology, as it stands, allows operation of many mapping
trees -- it is merely an issue of parametrizing the resolvers. Forcing
everybody in a single tree is not and should not be the role of the
IETF. You may want to document the consequences of operating one way or
another, and the pitfalls of each of the operation regimes; you should
not try to restrict the business practices of competing actors in the
market.

-- Christian Huitema

_______________________________________________
enum mailing list
[email-masked]
http://www1.ietf.org/mailman/listinfo/enum

---

From: "David R. Conrad" <[email-masked]>
Date: Tue, 20 Feb 2001 11:38:09 -0800

Christian,

At 09:12 AM 2/20/2001 -0800, Christian Huitema wrote:
>Forcing
>IETF.

Guess we should remove references to in-addr.arpa in the RFCs then.

Rgds,
-drc

---

From: "A.M. Rutkowski" <[email-masked]>
Date: Tue, 20 Feb 2001 15:35:51 -0500

Hi David

>Guess we should remove references to in-addr.arpa in the RFCs then.

in-addr.arpa was created when this was all the government's
network and anticompetitive considerations were not relevant.
It's continued provisioning very much enjoys antitrust
protection under government contract and derivative instruments.

--tony

---

From: Bill Manning <[email-masked]>
Date: Tue, 20 Feb 2001 20:18:16 -0800 (PST)

% Hi David
% 
% >At 09:12 AM 2/20/2001 -0800, Christian Huitema wrote:
% >>Forcing
% >>everybody in a single tree is not and should not be the role of the
% >>IETF.
% >
% >Guess we should remove references to in-addr.arpa in the RFCs then.
% 
% in-addr.arpa was created when this was all the government's
% network and anticompetitive considerations were not relevant.
% It's continued provisioning very much enjoys antitrust
% protection under government contract and derivative instruments.
% 
% --tony

	To say nothing of the tens of millions of copies of deployed 
	code that depend on its persistence.

--bill

---

From: "David R. Conrad" <[email-masked]>
Date: Tue, 20 Feb 2001 17:30:24 -0800

Tony,

>network and anticompetitive considerations were not relevant.

I'm sure Rick Adams and Marty Schoffstall (etc.) would have been interested 
to have heard this.

You seem to waver between the Internet either being a private network not 
subject to U. S. (or any other) government regulation or one which is owned 
by the (U.S. goverrnment).  I'll admit being confused as to what your view 
of the actual situation really is.

However, the point I was trying to make was countering Christian's 
assertion that the IETF shouldn't be establishing domains.  The IETF is in 
the business of specifying protocols of which the use of in-addr.arpa for 
associating names with addresses is one.  If this is, as you say, protected 
from antitrust concerns by the USG's magic wand, then it would appear to 
follow that e164.arpa would be protected as well.

Rgds,
-drc

---

From: "A.M.Rutkowski" <[email-masked]>
Date: Wed, 21 Feb 2001 08:46:11 -0500

Hi David,

>I'm sure Rick Adams and Marty Schoffstall (etc.) would have been 
>interested to have heard this.
>subject to U. S. (or any other) government regulation or one which is 
>owned by the (U.S. goverrnment).  I'll admit being confused as to what 
>your view of the actual situation really is.

The subject is multithreaded.  Prior to Rick/Marty/Bill, it was fairly
simple because it certainly was entirely the government's.  After that
point, bits (no pun intended) began to be divested to the private sector.
Some key functions, have been retained to provide the antitrust protection
and as Bob Kahn likes to say, a failsafe mechanism.  The only other option
that the USGOV is another government or an intergovernmental organization -
neither of which are really feasible.

>associating names with addresses is one.  If this is, as you say, 
>protected from antitrust concerns by the USG's magic wand, then it would 
>appear to follow that e164.arpa would be protected as well.

Except that we're creating de novo, an entirely
new infrastructure and marketplace, with a really
substantial scale and significance that Christian
points out.  Existence/protection will come with a
quid pro quo - namely that there will be some
rules of the road that the private sector working
with the government will agree on.  That's what
is taking place now.

If nothing else, this will be done if nothing else
to be sure that the wrong jurisdictions don't exercise
authority and regulate it - which in part is what
Computer II was all about.

--tony

---

From: "David R. Conrad" <[email-masked]>
Date: Wed, 21 Feb 2001 06:29:43 -0800

Tony,

At 08:46 AM 2/21/2001 -0500, A.M.Rutkowski wrote:
>simple because it certainly was entirely the government's.

I'd suggest that the folks who were at WIDE, AARNET, Tuianet, HARNET, etc. 
would find it amusing to be told that their networks were entirely the (US) 
governments.

The Internet is and always has been an interconnection of autonomous 
networks.  You know this -- you've argued it yourself on numerous 
occasions.  The fact that some of those networks were funded by the USG 
and/or some of those interconnections were sponsored as part of USG funded 
"cooperative agreements" would appear to be irrelevant in this context -- 
you might as well be arguing that by using highways, trucking companies are 
immune from antitrust considerations.

>>assertion that the IETF shouldn't be establishing domains.  The IETF is 
>>in the business of specifying protocols of which the use of in-addr.arpa 
>>for associating names with addresses is one.  If this is, as you say, 
>points out.

This is one view.  Another view is that we are simply mapping an existing 
infrastructure into the DNS.

Rgds,
-drc

---

From: "A.M. Rutkowski" <[email-masked]>
Date: Wed, 21 Feb 2001 10:11:39 -0500

Hi David,

>would find it amusing to be told that their networks were entirely the 
>(US) governments.
>
>and/or some of those interconnections were sponsored as

I recant on the breadth of my comment.  You're certainly right.

However, it terms of administrative control and backbone connectivity
and routing, it was certainly the U.S. government's.  The DISA NIC
controlled the entire administration until 31 Dec 1992, and we were
still nominally getting Steve Wolff's permission for lots of things
for a couple years afterwards.

>infrastructure into the DNS.

The catch is that that existing infrastructure is subject
to 120 some years of domestic and international regulatory
regimes.  If you adhere to the "simply mapping" model, then
you map that 120  years of baggage with it.

It's also worth noting that 1) NAPTR RRs which the most
innovative piece of the protocol goes way beyond just
PSTN interworking, and 2) DNS from a regulatory standpoint,
exists as a private networking service (with some antitrust
protection provided courtesy of the USGOV).

Frankly, you'll find the mapping model a hard sell in
Washington (and most other places that have moved beyond the
PTT era).  Try walking around the 8th floor of the FCC with
a Mr. ENUM suit, carrying a sign reading "regulate me."

cheers,

--tony

---

From: "David R. Conrad" <[email-masked]>
Date: Wed, 21 Feb 2001 21:00:42 -0800

Tony,

>you map that 120  years of baggage with it.

It remains unclear to me how you'd be able to get your cake (the ability to 
treat e.164 numbers in the DNS as they are treated in the PSTN) and eat it 
too (not require at least minimal adherence to the structures that make 
e.164 numbers work the way they do).

Nothing is stopping anyone from entering digits as domains.  Nothing is 
stopping anyone from using NAPTR RRs in those zones.  Where life gets 
complicated is when you try to make the exact same associations of 
"ownership" of the strings of digits in both the DNS and the PSTN without 
involving the bodies that are making the ownership associations in the PSTN.

>PSTN interworking,

True, given NAPTR is a part of the DNS and it is way beyond just PSTN 
networking but I'm not sure what the relevance is.

>and 2) DNS from a regulatory standpoint,

So you assert but which I remain unconvinced of.

>PTT era).

Whether or not you or Washington wishes to view it as mapping, the reality 
of the situation is that if 1-650-381-6003 and 
3.0.0.6.1.8.3.0.5.6.1.(whatever) NAPTR "tel:blahblahblah"  terminate at the 
same user, you ARE mapping those identifiers together.  That is 
reality.  The question is whether those mappings are deterministic.  A 
single tree approach insures the mapping are deterministic.  A multiple 
tree approach insures that they aren't (unless, of course, determinism is 
insured at an administrative level).

>Try walking around the 8th floor of the FCC with

You have said this before and I still find it amusing.  Why do you assume 
the FCC or other USG body won't regulate when people subject to scams and 
abuse come screaming at them?  Given the potential for abuse, I suspect the 
multiple root approach is much more likely to result in (much more) 
regulation than a single root approach, albeit that regulation will be 
reactive to abuses (new forms of slamming, cramming, etc.) instead of 
pro-actively establishing a model in which industry organizations can 
compete effectively without significant government intervention.

In any event, either way, Nominum doesn't care -- regardless of model, 
people will still need to provide DNS services... :-)

Rgds,
-drc

---

From: Dave Crocker <[email-masked]>
Date: Wed, 21 Feb 2001 22:09:21 -0800

At 12:35 PM 2/20/2001, A.M. Rutkowski wrote:
>>>Forcing everybody in a single tree is not and should not be the role of the
>>>IETF.

1. As the other David C. notes, your assertion about history is factually 
inaccurate.

2. Equally interesting is that you are now back to asserting the anti-trust 
is an issue.  However you have already admitted that a) you are not 
offering a professional opinion about current working group activities, and 
b) you are not asserting that current working group activities demonstrate 
any specific problems.

In other words, Tony, you said that you were just offering a generic 
concern, which clearly is of no immediate relevance.

However your ploy is equally clearly proving successful at distracting some 
participants and wasting list bandwidth.

Thanks so much.

>Washington (and most other places that have moved beyond the

Oh, boy.  Now THAT will certainly make the IETF quake in its boots.  I seem 
to recall that a similar line of threat was quite effective in getting the 
IETF to recommend watered-down security specifications.  (Not!)

>infrastructure into the DNS.

Especially due to the IETF's lack of any enforcement mechanism, that is not 
just "another view".

It is simply an accurate summary of this WG's mandate and activities.

d/

ps.     FOLKS, the way to avoid having to climb out of ratholes is to step 
around them.

         LET'S MOVE ON!

----------
Dave Crocker   <mailto:[email-masked]>
Brandenburg InternetWorking   <http://www.brandenburg.com>
tel: +1.408.246.8253;   fax: +1.408.273.6464

---

From: "A.M.Rutkowski" <[email-masked]>
Date: Thu, 22 Feb 2001 08:41:06 -0500

Hi David,

>It remains unclear to me how you'd be able to get your cake (the ability 
>to treat e.164 numbers in the DNS as they are treated in the PSTN) and eat 
>it too (not require at least minimal adherence to the structures that make 

Dealing with the systems integration (both technical and regulatory)
here is the designated function of the USGOV's ITAC-T SG-A ENUM AdHoc
group and the associated mailing list.  Part of that effort involves
finding a permanent sanctioned/protected forum for doing this.

The task is made rather more difficult 1) because of the significant
changes that have occurred in the PSTN world over the past 15 years,
within which PSTN numbers have been significantly involved, and
2) because the Internet regulatory construct rests on regulatory
forbearance.

>using NAPTR RRs in those zones.  Where life gets complicated is when you 
>try to make the exact same associations of "ownership" of the strings of 
>digits in both the DNS and the PSTN without involving the bodies that are 
>making the ownership associations in the PSTN.

It's not apparent that anyone is suggesting not involving the
relevant parties dealing with PSTN numbers.  In the Competitive Zone
ENUM provisioning model, the providers interact with those parties
on an autonomous business relationship or contractual basis.  In
the Special Status Zone model, it occurs through some well-defined
industry or government cooperative mechanism.  These could even
coexist in some fashion as suggested in the VeriSign-Telcordia
ENUM AdHoc presentation.
http://www.enumworld.com/resources/roadmap.ppt

ENUM DNS zones are only names based on PSTN numbers.
They are not the numbers themselves, and the legal
and public policy distinction is fundamental.

It's also worth emphasizing that even in the PSTN world, the
numbers are fully under the jurisdiction of national
Administrations, not intergovernmental bodies.  Some of
the fundamental constructs here have been misunderstood.
The ITU, for example, is purely a "Union" of independently
sovereign Member States.  The organization itself has essentially
no independent powers, enforcement or even certification
authority.  Only the Member States, acting through the
Plenipotentiary Conference, or provisionally through
the Council, can enter into "agreements;" and any Member
State can opt out. See Art. 8 j) (No. 58) ITU Constitution.

>networking but I'm not sure what the relevance is.

The point was that the ENUM protocol enables much more
than just a mapping of a phone number to some Telephony
resource.  It can and is certainly expected to support a
broad array of messaging, presence, and other potential
services enabled by the NAPTR algorithm.  A significant
general purpose infrastructure in being put into place
here - which invokes the interests of many parties other
than just existing providers and institutions.

>So you assert but which I remain unconvinced of.

You can 1) read the cases, or 2) contact your favorite
antitrust counsel or government official.

>deterministic.  A multiple tree approach insures that they aren't (unless, 
>of course, determinism is insured at an administrative level).

It's not clear that any alternative "insures" anything.  Different
schemes affect the levels and distributions of probability,
administrative complexity, innovation, and costs.  These are all
well-known tradeoffs to governance policy communities.

>abuse come screaming at them?  Given the potential for abuse, I suspect 
>the multiple root approach is much more likely to result in (much more) 

US regulatory policy - particularly for the Internet - is heavily
grounded on forbearance.  There is a significant difference between
regulation and intervention.  A good example recently occurred when
the FTC intervened to bring actions against some DNS scam artists.

>people will still need to provide DNS services... :-)

However, the choices will affect the size and dynamics of
the marketplace for all of us.

best,
tony

---

From: Richard Shockey <[email-masked]>
Date: Thu, 22 Feb 2001 10:38:37 -0500

At 08:41 AM 2/22/2001 -0500, A.M.Rutkowski wrote:
>>to treat e.164 numbers in the DNS as they are treated in the PSTN) and 
>>eat it too (not require at least minimal adherence to the structures that 
>>make e.164 numbers work the way they do).
>

For once I actually agree with you Tony ... the need for a new forum for 
these industry discussions moving forward is very clear....but it must 
clearly be neutral to the existing positions out there.

Its perfectly acceptable to continue using this list to talk things out 
..but beyond that something more concrete has to be done since the IETF is 
not the forum for crafting regulatory and policy issues in the US or any 
other country for that matter.

Richard Shockey, Senior Technical Industry Liaison
NeuStar Inc.
1120 Vermont Avenue N.W., Suite 550, Washington DC. 20005
Voice: 202.533.2811,  Cell : 314.503.0640,  Fax: 815.333.1237
<mailto: [email-masked]> or
<mailto: [email-masked]>
<http://www.neustar.com>
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

---

From: "David R. Conrad" <[email-masked]>
Date: Thu, 22 Feb 2001 12:51:46 -0800

Tony,

At 08:41 AM 2/22/2001 -0500, A.M.Rutkowski wrote:
>relevant parties dealing with PSTN numbers.

Realistically, I can't imagine the multiple root proposal resulting in 
anything but this.

>In the Competitive Zone
>on an autonomous business relationship or contractual basis.

As I asked previously and never got a response:  what if those providers, 
which include PTTs outside the US, have no interest in entering into 
contractual relationships with some random company in some random 
country?  Particularly given the established international cooperative body 
of those providers has their own infrastructure that provides the exact 
same thing in a well understood and binding fashion?

The impression I have gotten is that in those cases, the tier I registry 
could, if they so chose, enter into contractual relationships with the 
subscriber.  At this point, you get into really complicated problems 
associated with the rights of the provider to disassociate services with a 
particular number.  No one has yet answered my questions on how this was to 
be addressed in the competitive zone model.

>and public policy distinction is fundamental.

I don't disagree.

>Administrations, not intergovernmental bodies.

As is the case with the 2916 approach.  Delegation is done to member states 
as delegation of the existing telephony country codes is done to member 
states (modulo the cases like country code "1" in which multiple member 
states fall under a single code).

>Some of

I don't think so.  I suspect it is fully understood by the folks involved 
in writiing 2916 that delegations within the e164.arpa space would occur at 
the behest of the member-state, not the ITU itself.

>resource.

This is a red herring.  The NAPTR RR is not tied to any e.164 numbering 
scheme, you can put NAPTR RRs in any zone.  What is being discussed is the 
situations in which NAPTR RRs are tied into zones with particular 
semantics, namely the use of particular number strings as they are used in 
the PSTN.  If you are not interested in these semantics, then I can't 
imagine anyone having any issue with what you're calling the competitve 
zone model.  The issues arise when you attempt to impose existing PSTN 
semantics on a system that is not required to correlate with the structures 
that define those semantics.  Having your cake and eating it to is _hard_.

>regulation and intervention.

Undoubtedly so.  However, the end result is the same in that in both cases 
you have regulation.  My personal feeling is that it would be preferable to 
have an environment that tries to limit the need for intervention instead 
of encourage it.

Rgds,
-drc

---

From: "A.M. Rutkowski" <[email-masked]>
Date: Thu, 22 Feb 2001 17:17:21 -0500

Hi David,

>country?  Particularly given the established international cooperative 
>body of those providers has their own infrastructure that provides the 
>exact same thing in a well understood and binding fashion?

This problem is actually much aggravated under the Designated Zone model.
There is no "own infrastructure that provides the exact same thing in a
well understood and binding fashion."  These matters are dealt with today
through direct commercial relationships, not the ITU.  The old CCITT
Routing Plans and formal notifications via the Secretariat went out a long
time ago.

With the Designated Zone model, that's all a country or a provider need do
to sandbag ENUM provisioning within their region is to opt out.  You can
expect that a great many will...and/or take a long time to move.  The
Competitive Zone model enables providers to devise their own schema for
working around the PTT/Administration intransigence problem.

>particular number.  No one has yet answered my questions on how this was 
>to be addressed in the competitive zone model.

This is a complicated legal problem that exists under both models,
and where an industry cooperative forum could work out provisioning
guidelines.

>As is the case with the 2916 approach.  Delegation is done to member 
>states as delegation of the existing telephony country codes is done to 
>member states (modulo the cases like country code "1" in which multiple 
>member states fall under a single code).

It's the wrong model.  States are sovereign.  No one delegates to them.
They agree among themselves what numbers they use.  The significant
flaw is that under the Designated Zone model, the e164.foo zonekeeper
is reserving a nn.e164.foo sub-zone for the same party that controls
the tel:+nn PSTN number.  If that party opts out, you end up denying
service to all potential users in that sub-zone.

>in writiing 2916 that delegations within the e164.arpa space would occur 
>at the behest of the member-state, not the ITU itself.

That's not the way it reads.  A national Administration, for example,
(which is easily identified in the ITU Global Directory) could not
go to the administrator to the e164.arpa zone and direct the entry
of a RR in the zonefile.

This is hypothetical, fortunately, because 2916 is a nullity.

>semantics on a system that is not required to correlate with the 
>structures that define those semantics.  Having your cake and eating it to 
>is _hard_.

What did those red herring do to deserve such treatment. :-)
You misunderstood my remarks - which had nothing to do with disassociation -
but rather that there are diverse applications and market sectors involved
here other than just telephony and telephone providers.  You might just
want to use your ENUM record, for example, to point to a Instant Messenger
name.

>you have regulation.  My personal feeling is that it would be preferable 
>to have an environment that tries to limit the need for intervention 
>instead of encourage it.

Intervention by a regulatory agency like the FTC in cases
of demonstrated abusive consumer practices is definitely
different than imposition of a regulatory regime like
Common Carrier regulation.

Few officials these days prefer the latter over the former,
especially for new Internet based services.

Try dressing up in a Mr. ENUM suit with a "Regulate Me"
placard and see how many commissioner's offices you can
get into over on the 8th floor of the FCC.  If nothing
else, you'd make the business section of the Washington
Post. :-)

best regards,
tony

---

From: "David R. Conrad" <[email-masked]>
Date: Thu, 22 Feb 2001 18:40:20 -0800

Tony,

At 05:17 PM 2/22/2001 -0500, A.M. Rutkowski wrote:
>The Competitive Zone model enables providers to devise their own schema for

If you are working around the PTT/administration, it seems unlikely you 
would be working with them in validation, no?

What you appear to be proposing is that if a member state decides, for 
whatever reason, not to have its country code delegated into the e164 
space, that private parties should go ahead and do the delegations 
themselves.  While an interesting way to bypass those member state's 
wishes, the implication is that you would not get that member state's 
cooperation in the validation that your model requires for consistency.

>and where an industry cooperative forum could work out provisioning

It is only complicated because you are proposing a Byzantine delegation 
structure that does not conform to the semantics of the object you are 
trying to delegate.  I am skeptical that an industry forum could be created 
that can address these issues domestically, much less 
internationally.  However, attempting to come up with such (and dealing 
with the inevitable issues that subsequently arise) will undoubtedly 
provide lawyers with more things to do.

>They agree among themselves what numbers they use.

Sorry for the shorthand notation.

>The significant
>the tel:+nn PSTN number.

Of course.  That is the authoritative party for that object.  How are you 
going to validate the PSTN number is delegated to the appropriate body if 
the authoritative party doesn't participate in the validation?  Guess?

>If that party opts out, you end up denying

Ignoring, for the moment, exactly why a member state would opt out (and the 
implications of that action), if that party opts out, how are you going to 
validate the users in space that party is responsible for are justified in 
their request?

Rgds,
-drc