On 18 May 2019, at 10:38 PM, Ronald F. Guilmette <r...@tristatelogic.com> wrote:
> 
> In message <beeb33f0-d800-4099-b5a7-8ad232dc8...@arin.net>, 
> John Curran <jcur...@arin.net> wrote:
> 
>> Ronald -
>> 
>> However, it is quite likely that the state registration issue would have
>> been promptly corrected once raised, at which point we would have ended up
>> with the same outcome.
> 
> It's an arguably valid point, but I disagree, for the following reasons.
> 
> It's one thing to try to run a fraud against a non-governmental private
> non-profit organization, like ARIN, which has both a strong incentive
> never to litigate and also a strong and widely-known history of vitrually
> never doing so.  It is quite another thing entirely to commit a fraud
> where the gateway requirement to begin the scam is to perpetrate at least
> a portion of the fraud against one or more of these United States.

Ronald - 

        Incorrect - a party that retains someone to notarize fraudulent 
documents for submission to ARIN is already well over that line, with both 
state and federal statutes violated.   

        For the additional state registration to be a deterrent for such 
parties, they’d effectively be of belief that “We’re not worried about the 
federal wire fraud charges we’ll be facing, nor our existing state fraud we’re 
perpetrating with our specious corporation registration in our home state, but 
_are_ deeply concerned about the tax registration in second state, so let’s 
quit now.”   

        Can you explain why the additional crime is particularly burdensome?

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers

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