Dear Partners,
>From EUROPOL perspective, we observe with interest, the proposed measure, >considering the digital investigation matters, While consulting colleagues also at national level and partners, we have identified various points on which we would thank you to bring information, for our better understanding. 1) With the addition of the nibble boundary, how do we ensure that the policy complies with the "Registration goal", which is essential for Internet troubleshooting and avoiding abuse? Are PIs required to register End Site information ? What type of information is recorded by PI and how is this information made accessible to a requesting Authority? What type of information is recorded by the End User, for example about his End-Sites? How they provide information when requested by an Authority, ensuring that they comply with "Registration goal"? How to ensure that an IP range is used by a single party and not more? 2) When a PI receives a larger prefix for more than one End-Site instead of two smaller prefix, how they have to distribute IPs in those range? Are they obliged to distribute them evenly, or can they simply use most of them at one of the End-Sites and leave some others at the remaining site? How to prevent the "Fragmentation" of a larger prefix between different End Sites (instead of having them use contiguous IP ranges)? Couldn't they just demonstrate the need of small End-Sites to get a larger pool of IPs for a single End-Site (or stockpiling them), violating the "Conservation goal"? 3) How to avoid unlawful internal renumbering in case of end-site growth after assignment of a larger prefix? 4) How should the relationship between an End Site and a newly acquired interval be recorded by PI? How the PI should manage the reverse lookup and how the PI delegates to end-user organizations the responsibility of managing the reverse lookup zone corresponding to the given address? 5) How to prevent PI being abused for providing ISP services and how to get information about the End Users if it happens? 6) Where are the Authorities supposed to get information about who is the entity using the /56 prefix range if there is no sub-assignment? Thanks for your cooperation Regards Emmanuel Kessler O3 European Cyber Crime Centre (EC3)
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