Appeal of IESG Decision of July 10, 2006
Legal Disclaimer: In places this document refers to legal obligations and demands on certain organizations and individuals. It should be noted that this document is not submitted as a complete or final description of any legal demands that might be made by Anderson or Av8 Internet or others, but is submitted only for due process consideration by superior management. No limitation on rights is accepted nor are any specific legal theories offered. These references are to be taken only as preliminary notices of infringements and preliminary demands to cease and desist, according to our prudent duties to make such notices and demands known.
Summary of Issues for the IAB
In the Articles included, a number of issues are raised involving:
Errors in Decision of IESG Appeal of July 10, 2006
Untruthful Statements in IESG Decision
Defamatory False Reports by IESG
Breaches of Duties by IESG Members.
We ask the IAB to reverse the errors, disavow and repudiate the false statements and defamatory false reports, and discipline the IESG board members for breaches of duties and bad faith.
Table of Contents
Table of Contents. 1
Article I. Last Call Comments as Means of Resolution 4
Article II. Disloyalty and Cover-Up by the IESG 5
Section 2.01 Bad Advice by IESG Members: No Appeal to IAB for Failure to Act on Last Call Comment 5
Article III. Sufficient Grounds for Dispute Given 6
Section 3.01 Procedure for Dispute of Last Call Decisions 6
Article IV. Activities and Publications Outside the IETF 8
Section 4.01 Karrenberg part of ISOC 8
Section 4.02 Duties Owed to ISOC 9
Section 4.03 Collaboration with Other Organizations Allowed 9
Article V. Notice of Evidence of Fraudulent Data 9
Section 5.01 Good and Sufficient Evidence Given 9
Section 5.02 False Report of No Evidence 10
Article VI. Appeals Process Appropriate for this Dispute 11
Section 6.01 Cover-up: Misrepresentations and False Reports 12
Article VII. Benefit of Rules and procedures 12
Section 7.01 Who Benefits from the Non-profit Corporation? 12
Article VIII. Appeal Process Followed 13
Section 8.01 Fraudulent Misrepresentation and False Report 14
Article IX. Defective WG Chair Decision on Last Call 15
Section 9.01 Deception by Kessens 15
Section 9.02 Deception Central 16
Section 9.03 Inconsistent Statements and Actions; Deceit 16
Section 9.04 Estoppel to assert Consensus in December 2005 17
Section 9.05 GROW WG Ignorant of Scientific Fraud in June. 17
Section 9.06 Dubious July Last Call 18
Article X. Conflict of Interest of IESG Members 18
Section 10.01 Notice of Evidence Substantiating Allegations Given 19
Section 10.02 False Report of Unsubstantiated Allegations 19
Section 10.03 Conflict of Interest 19
Section 10.04 Conflict of Interest: Carpenter and Kessens; Collusion 20
Section 10.05 Conflict of Interest: WG Chair Huston 20
Section 10.06 Misstatements of Adverse Party and Unfair Dealing 20
Section 10.07 Improvident Bargain for ISOC 21
Section 10.08 Fiduciary Duties to ISOC 21
Article XI. Call for Investigation 21
Article XII. False Report of Disruptive Misconduct 22
Section 12.01 False Report of “fundamentally wrong” allegations 22
Section 12.02 Relevance of Allegations to GROW WG Document 23
Section 12.03 Actual Evidence of Fraud Unnecessary for Relevance of Allegations 23
Section 12.04 False Report of Disruptive Activity 23
Section 12.05 Pattern of False Reports 24
Section 12.06 Improper Motive Actuating Conduct 24
Section 12.07 Bad Faith of IESG: Complaint Process not “Disruptive” 24
Background of Dispute
Beginning in November, 2002, two companies ISC and RIPE-NCC, began promoting a controversial stateful Anycast technique for DNS. In 2003, Anderson became aware of efforts to disparage, discredit, and defame Anderson, that were associated with ISC and another apparently unincorporated anti-spam group, SORBS. Some of this activity took place on ISOC activities and Working Groups and ISOC employees performed some of this activity. During this time, Anderson made complaints about this inappropriate activity to ISOC management: Working Group Chairs, the Chair of the IETF, the IESG, and the IAB.
The topic of stateful Anycast was discussed on the DNSOP Working Group many times between 2002 and 2004. The DNSOP group found no consensus to support the practice. In October 2004 data was obtained and reported by Verisign that demonstrated the stateful Anycast technique was unsafe. On November 1st, 2004, Joe Abley of ISC submitted the first draft of the Document draft-ietf-grow-anycast (herein “Document” or “draft-ietf-grow-anycast”), which underlies much of this dispute. On November 7th, 2004 and since, Daniel Karrenberg disputed the Verisign data from October. In May 2005, Daniel Karrenberg, published a report asserting that he had performed testing that demonstrated the stateful Anycast technique was safe, and that statements and data to the contrary was a “false rumor”. In September 2005, David Kessens threatened to silence Anderson for revealing problems that stateful Anycast causes for Secure DNS (DNSSEC). This threat and related issues are the subject of another (related) Appeal process that is currently being raised to the ISOC Board of Trustees level. The IAB level Appeal, submitted to the IAB on April 18th, 2006, and its response, may be found on the Appeals page of http://www.iab.org/ website.
On November 5th, 2005, Huston tries to determine consensus on the draft-ietf-grow-anycast Document by issuing a Working Group Last Call. There is comment during this period, but on November 22nd, Huston asserts that a consensus has been observed because there were no comments against the Document. On November 30th, Anderson disputed Huston’s assertion of no comment. Huston responds with a correction. On December 2nd, Anderson, thinking that Huston is reporting a made decision, cites reasons that the document is not ready. In response, and contrary to the statement by Huston on November 22nd, the document state is not moved to [IETF] “Last Call Requested”. In January 2006, a new version of the Document is issued. In January 2006, a new version of Document is produced.
In January 2006, Anderson obtains the source to the DNSMON program and learns that Karrenberg has not performed stateful Anycast testing, and that Karrenberg has falsified the results published in May 2005. Anderson notifies the IESG in March, 2006 and the IAB in April 2006, of this discovery, and that Karrenberg’s testing has no relevance to stateful Anycast stability, and that Karrenberg’s data does not truthfully dispute either Anderson et al’s analysis nor Verisign’s October 2004 data. In June 2006, without any notice to the Working Group and after six months with no discussion of the draft-ietf-grow-anycast Document, David Kessens moves the Document to state [IETF] “Last Call Requested”. Anderson files an Appeal with the IESG on June 2nd, 2006. The IESG tries to “not accept” this appeal, and instead tries to persuade Anderson to file the complaint as a “Last Call Comment” instead. On June 14th, 2006, after extended discussion with the IESG  , Anderson files an amended Appeal. On July 10th, 2006, the IESG responded and rejected all parts of the June 14th Appeal  .
The IESG Response dated July 10th, 2006 does not dispute any specific fact asserted in the June 14th Appeal nor any specific fact in the referenced Appeal to the IAB dated April 18th, 2006. The July 10th Response instead makes conclusory statements which contradict the evidence of facts and events and notifications asserted by Anderson, and also makes additional statements which are disputed herein. Articles I through XII of this Appeal address the July 10th, 2006 IESG Response.
The IAB Response  on July 13th, 2006 to the April 18th, 2006 Appeal  by Anderson, through related, is not addressed in this Appeal. That matter is the subject of an Appeal to the ISOC Board of Trustees that will be filed shortly.
This Appeal to the IAB also touches on the issues of conflict of interest, duties and status of managers of the IETF/IESG/IAB as employees of ISOC. These issues will be fully addressed in an Appeal to the ISOC Board of Trustees to be filed shortly.
Article I. Last Call Comments as Means of Resolution
The IESG writes in Section 1 of its July 10th, 2006 Response:
“A Last Call does not imply that the IESG is necessarily supportive of a document; in fact issuing a Last Call is a perfectly reasonable way for the IESG to solicit input about a document’s suitability for publication”
First, a pre-requisite to an IETF Last Call is an observation of consensus. But the June 14th Appeal filed by Anderson includes more issues than just whether the document is suitable for publication. The Appeal involved issues of:
whether the quality and integrity of the document was properly addressed;
whether statements made to the IESG in the datatracker comments by Area Director David Kessens were accurate;
whether the objections were properly heard,
and whether the IESG has properly reviewed the propriety of IESG members’ actions on this subject.
Though these issues also make the document unsuitable for publication, none of these issues can be fully resolved in a passive “Last Call Comment”. Further, the WG appeals process had been exhausted  . To the extent that some issues could be resolved through several processes, the member has the option to choose the method of complaint. IESG Board Member Sam Hartman asserted that the Appeals process is somehow confrontational,  however, there seems to be no reasonable basis for asserting that a choice of formal process is inappropriate. Therefore, an Appeal to the IESG is an appropriate means of resolution.
Article II. Disloyalty and Cover-Up by the IESG
The IESG made efforts to dissuade Anderson from filing an Appeal  . These efforts evidence an effort to cover-up misconduct of IESG board members by IESG board members. As shown by the IESG discussion, IESG board members made very insistent efforts to persuade Anderson to submit his complaints as a “Last Call Comment”. The GROW WG Chair took Anderson’s IESG Appeal as an appeal to the WG Chair, and issued a rejection. IESG board members Carpenter and Kessens also complained that the original June 2nd Appeal was too vague for action. This doesn’t seem to be a valid objection since the first appeal indicates several improper actions and cites two grounds for action, specifically RFC 2026 § 6.5.1 and RFC § 6.5.2, and describes several improper activities:
Incorrect technical choice (due to scientific fraud) [RFC 2026 § 6.5.1]
Objections not heard (no proper consideration of fraud) [RFC 2026 § 6.5.1]
Pre-requisite for consensus not met [RFC 2026 § 6.5.2]
Anderson eventually submitted an Amended Appeal with very specific requests for actions on June 14th, 2006.
The IESG is ethically and legally obligated to act according to the ISOC Corporate Charter and Bylaws and by its own adopted rules, consistent with the ISOC rules. Whenever the IESG becomes aware of misconduct, it has a duty to act accordingly in the interests of the ISOC Corporate entity. Yet, there has been no investigation of the allegations in this and previous appeals. There is little written documentation of any kind of investigation, in an organization that produces documents analyzing technical questions. IESG Board Member Sam Hartman even pleaded ignorance of the Karrenberg Fraud in June 2006, despite having notice in March 2006.  This seems beyond mistake. The prior Appeals submitted by Anderson document even more unusual activity. In the instant case of the GROW WG dispute, Hartman and Carpenter have very insistently sought to use a very informal process rather than a formal process, where an investigation is more visibly needed. A pattern has become apparent: The IESG board members have, affirmatively and actively, tried to cover-up the misconduct of its members and by ISOC Trustee Daniel Karrenberg.
Section 2.01 Bad Advice by IESG Members: No Appeal to IAB for Failure to Act on Last Call Comment
The IESG board members’ advice and persuasion of Anderson in this matter furthers the improper effort to conceal misconduct. As already documented, in June, IESG board members insistently attempted to persuade and advise Anderson to submit his complaint as a “Last Call Comment”, prior to accepting the Appeal. The IESG decision of July 10, 2006, also asserted that the issues in Anderson’s complaint were somehow more appropriately submitted to the IESG as a “Last Call Comment” instead of as an Appeal under RFC 2026. Examining the “Last Call Comment” process reveals the prospective operation of a method of concealment of misconduct: Should the IESG choose to ignore a Last Call comment, there is no appeal process for failing to act on Last Call comments. Furthermore, Last Call comments are not made public; the comments may not be easily learned by the ISOC management nor easily obtained, if at all, by other ISOC members. A Last Call comment can easily function as a “blackhole” in which complaints go in, but no one outside the IESG board is aware of such complaints. Thus, IESG board members are not properly held accountable for misconduct through the informal process they so insistently promoted. This violates a duty  to give information to the ISOC, and is done on account an interest adverse to the ISOC, and with personal interests conflicting with those of the ISOC. The conflicting personal interests and adverse interests have been documented in prior Appeal of PR-action submitted by Anderson to the IAB and IESG.
The ISOC Corporate entity has a right to the loyalty, due care, and obedience of the IESG board members  . The IESG “advice” in this regard should be considered in light of the pattern of conduct to cover-up misconduct of IESG members. The bad advice and attempted cover-up by IESG board members shows those IESG board members’ loyalty to other board members and to adverse and conflicting interests, instead of to the ISOC.
Article III. Sufficient Grounds for Dispute Given
The IESG response states incorrectly in Section 1:
“The grounds given in the appeal therefore cannot invalidate the decision to issue a Last Call”.
This statement necessitates a review of the procedure and grounds for which a Last Call decision can be contested and possibly invalidated.
Section 3.01 Procedure for Dispute of Last Call Decisions
The draft-ietf-grow-anycast Document is on track to become a BCP. Section 5.1 of RFC 2026 describes the BCP Review Process:
“Specifically, a document to be considered for the status of BCP must undergo the procedures outlined in sections 6.1, and 6.4 of this document.”
Section 6.1 of RFC 2026 describes standards actions such as IETF Last Call:
“A standards action is initiated by a recommendation by the IETF Working group responsible for a specification to its Area Director…”
The working group must make a recommendation. The procedure to make a recommendation is described in RFC 2418 § 7.4:
“In most cases the determination that a WG feels that a document is ready for publication is done by the WG Chair issuing a working group Last-Call. The decision to issue a working group Last-Call is at the discretion of the WG Chair working with the Area Director”
Although this section gives the WG Chair and Area Director discretion in their decision-making, their decisions must still be reasonable, open, and fair. The discretionary decisions of the WG Chair and Area Director are still properly subject to oversight including dispute and appeal to the IESG according to RFC 2026 § 6.5. The discretion given does not give the WG Chair or Area Director authorization to act unreasonably or dishonestly, nor does it mean that such decisions can’t be appealed under RFC 2026 § 6.5. Discretion does not give the WG Chair or the Area Director consent to act as or for adverse interests or with conflicting interests. 
RFC 2026 § 6.5 states:
“Disputes are possible at various stages during the IETF process. […] To achieve the goals of openness and fairness, such conflicts must be resolved by a process of open review and discussion”
Note that “Last Call” is a stage of the IETF process. Various grounds for disputes are outlined in RFC 2026 § 6.5.1, § 6.5.2, and § 6.5.3, and an appeals procedure is defined in §6.5.4. In summary:
§6.5.1 Working Group Disputes:
“(a) his or her own views have not been adequately considered by the Working Group (b) the Working Group has made an incorrect technical choice which places the quality and/or integrity of the Working Group’s product(s) in significant jeopardy.”
§6.5.2 Process Failures:
“[…] it is the IESG is charged with ensuring that the required procedures have been followed, and that any necessary prerequisites to a standards action have been met”
§6.5.3 Questions of Applicable Procedure:
“Further recourse is available only in cases in which the procedures themselves (i.e., the procedures described in this document) are claimed to be inadequate or insufficient to the protection of the rights of all parties in a fair and open Internet Standards Process.”
Only one of these described grounds are necessary for the IESG to invalidate a Last Call decision by a WG Chair and the Area Director.
Anderson asserted grounds of RFC 2026 §6.5.1 and §6.5.2. These grounds are sufficient for the IESG to invalidate the Last Call. Therefore, the IESG erred by asserting that the grounds given in the appeal cannot invalidate a decision to issue a Last Call.
Article IV. Activities and Publications Outside the IETF
The IESG writes in its response in Section 1:
“The IESG will take no position on allegations about activities and publications outside the IETF.”
This statement by the IESG is a frivolous objection and excuse not to investigate alleged misconduct and fraudulent scientific claims given as cause of action in the June 14th Appeal. The IESG, as a delegated management body of the ISOC, has a lawful duty to inquire and investigate those allegations. However, the statement, on its face, doesn’t stand up to scrutiny.
Section 4.01 Karrenberg part of ISOC
Daniel Karrenberg, the Chairman of the ISOC Board of Trustees, wrote the publication referenced in the Appeal. The ISOC is the corporate home of the IETF, the IESG, and the IAB  . Thus, the publications and activities of Mr. Karrenberg are not “outside the IETF”. Further, the publication in question is the only scientific document asserting the stability of the stateful Anycast technology being considered by the IETF GROW Working Group. The quality and integrity of this published document is directly relevant to the quality and integrity of the Anycast draft being appealed, and therefore relevant to a dispute under RFC 2026 § 6.5.1. It is a sham to attempt to exclude the integrity failure evidenced in this document and the DNSMON program written by Karrenberg et al, to exclude the evident integrity failure of the Chair of the ISOC Board of Trustees, author of that published document. The attempted exclusion of material documents is evidence of a cover-up by the IESG of misconduct by Karrenberg and others.
Section 4.02 Duties Owed to ISOC
The IESG has a delegated duty of management  that includes duty to inquire, and a lawful duty to give information to the ISOC.  The IESG statement that it “would take the usage or influence of fraudulent data in IETF WG decisions very seriously” implies that such information is relevant to the principal and would affect the desires of the principal, the ISOC. 
Section 4.03 Collaboration with Other Organizations Allowed
The IESG claim that it will take no position on activities and publications outside the IETF is also contrary to the ISOC statement on Purposes and Goals  that includes collaboration with other organizations on research.
Article V. Notice of Evidence of Fraudulent Data
The IESG writes in its response in Section 1:
“The IESG would take the usage or influence of fraudulent data in IETF WG decisions very seriously, but is aware of no evidence that this happened in this case. Any allegations of such matters should be accompanied by evidence of truth and relevance, […]”
Section 5.01 Good and Sufficient Evidence Given
In fact, the IESG was presented with good and sufficient evidence by the Appeal. The supporting evidence was provided in the form of citations and URLs to the source documents. This evidence is good and sufficient to verify the claims made in the allegations, as required of prima facie evidence.
Fraudulent Misrepresentation  : A false statement of a material fact, made with intent that another rely thereon, which is believed by the other party and on which he relies and is induced to act and by which he does so to his injury, and statement is fraudulent if speaker knows the statement to be false or if it is made with utter disregard of its truth or falsity.
The Appeal notified the IESG of good and sufficient evidence of Kessens affirmative misrepresentation of Anderson’s position in the datatracker questionnaire. Besides that evidence, the IESG, and particularly Kessens, is aware, inter se, of Anderson’s position: Kessens has spearheaded the efforts to suppress discussion of those views for almost a year, and brought Anderson up on false charges of disruption for discussing the same issue.  Kessens was an author of that document. Kessens was also involved (improperly Anderson asserts) in the Appeal of the PR-action, which reported the discovery of the Karrenberg Fraud. It is unreasonable to conclude that Kessens was somehow unaware of Anderson’s views on the subject. Other IESG members rely on and use the information in the IETF Datatracker Questionnaire in their decisions, and the claim was made with utter disregard to the truth, making the misrepresentation fraudulent.
The Appeal also notified the IESG of good and sufficient evidence of Karrenberg’s falsified Anycast research claim. The Karrenberg evidence isn’t particularly difficult to understand: Karrenberg didn’t perform stateful Anycast testing; he didn’t reveal this relevant fact, yet he still misrepresented his data as being relevant to stateful Anycast and refuting claims that stateful Anycast was unreliable. While Karrenberg didn’t explicitly say that he made stateful TCP queries (indeed Karrenberg didn’t say anything at all about this very important detail–this is a dishonest omission), Karrenberg did say that his results refuted the “false rumor” that Anycast was somehow unsafe–this is a dishonest statement. An honest statement would have said that his data had no bearing on the question of whether stateful Anycast was safe. The allegations can be verified by examining the paper published by Karrenberg, and the program written by Karrenberg, as cited by Anderson in the Appeals to the IESG in March 2006, and to the IAB in April 2006.
The Appeals by Anderson notified the IESG and the IAB of mounting evidence. But the IESG and the IAB did not impeach, question, explain, or contradict this evidence. Therefore, the assertion by the IESG that it “is aware of no evidence that this happened” is a further affirmative misrepresentation approved by the IESG  . The IESG members who participated in this false report are responsible for breach of duties to the ISOC. The statement is an affirmative misrepresentation of facts with the intent that others rely on it, made to superior management and, to the directors of the Corporation and to the members of the Corporation.
Section 5.02 False Report of No Evidence
As stated in Section 4.02 , the IESG has a lawful duty to give information relevant to the superior management established by the ISOC. Instead, the IESG willfully refused to perform its duties to examine “activities and publications outside the IETF” which are relevant to IETF documents, and gave a false report that the IESG is not aware of any evidence to support the allegations. The statement by the IESG asserting that allegations of fraudulent data were not accompanied by evidence of truth and relevance is an affirmative misrepresentation with intent that other rely on it, and a defamatory false report.
Article VI. Appeals Process Appropriate for this Dispute
The IESG writes in Section 1:
In fact, according to section 6.5 of RFC 2026, the appeal process exists to handle disputes that cannot be handled through normal process:
…This section specifies the procedures that shall be followed to deal with Internet standards issues that cannot be resolved through the normal processes whereby IETF Working Groups and other Internet Standards Process participants ordinarily reach consensus.
The quote from Section 6.5 is used incorrectly. The text says and means that Section 6.5 specifies the procedures to deal with issues that cannot be resolved by the normal processes. The text does not say that the appeal process exists to handle only disputes that cannot be handled through a normal process, but rather the section specifies procedures to deal with issues that, by definition, cannot be resolved by the normal process. It then enumerates those issues.
Indeed, there is no normal process to report misconduct of Working Group Chairs and Area Directors. In fact, reading further in Section 6.5 of RFC 2026, there are procedures that identify specific kinds of disputes which can’t be resolved through the normal process, and for which the appeals process is appropriate. Anderson’s Appeal contains several disputes in categories described by RFC 2026 § 6.5.1 and § 6.5.2..
The IESG writes in Section 1:
“The appeals process is not an appropriate tool to use when the normal process can be used to resolve the dispute. In this instance, the anycast document was in IETF Last Call at the time of appeal. The IETF Last Call process may be used to bring up any of the questions Mr Anderson has brought up against the anycast document, including the question of whether that document should have been last called. This appeal was an inappropriate use of the appeals process.”
As previously demonstrated in Section 3.01 , “Last Call” is a stage in the IETF process and subject to appeal to the IESG. So the June 13, 2006 Appeal by Anderson is appropriate use of the appeals process. The IESG erred by asserting that Anderson’s Appeal was an inappropriate use of the appeals process.
Improper decision of WG Chair
Misrepresentation by Area Director
Questions of Quality and Integrity
Views not Heard
Section 6.01 Cover-up: Misrepresentations and False Reports
The pattern of conduct suggests an improper object of, and in bad faith, covering-up and concealing the misconduct and misrepresentations stated in the Appeal. This pattern of conduct cannot be dismissed as merely a series of honest mistakes. In Article I it was shown that the issues raised in the Appeal cannot be adequately addressed in a passive Last Call Comment. In Article II it was shown that there is no appeal to an ignored Last Call Comment, and that submitting the complaint in this form was bad advice and contrary to the interests of the members and the ISOC. In Article VII the notion that there is somehow no benefit to adhering to rules and procedures is refuted. In Article III it was shown that sufficient grounds for a Appeal were stated. The IESG statements are a pattern of affirmative misrepresentations and false reports with the intent that members and superior management rely on them.
Article VII. Benefit of Rules and procedures
The IESG writes in Section 1:
“The IESG did not request suspension of the Last Call because this would benefit nobody.”
Abiding by, upholding, and enforcing the rules, procedures and principles of the IETF and ISOC are necessary to a fair and open, and objective process. This process, properly managed, benefits the members of the IETF and ISOC, and the public interest.
The rules of the ISOC and the IETF activity exist to benefit the public interest. RFC 2026 § 1.2 states
“These procedures are intended to provide a fair, open, and objective basis for developing, evaluating, and adopting Internet Standards. They provide ample opportunity for participation and comment by all interested parties. At each stage of the standardization process, a specification is repeatedly discussed and its merits debated in open meetings and/or public electronic mailing lists, and it is made available for review via world-wide on-line directories.”
Section 7.01 Who Benefits from the Non-profit Corporation?
Supposing it true for the sake of argument that ‘suspension of the Last Call … would benefit nobody’, the question is then, who would benefit from the improper approval of the draft-ietf-grow-anycast Document? It seems logical that someone must benefit in order to motivate Kessens to make false statements in the datatracker, and for Kessens and Carpenter to act on account of adverse and conflicting interests. And how does promoting a scientific fraud and covering-up serious questions serve the noble scientific purposes stated in the ISOCs Articles of Incorporation? The answer is that the adverse and conflicting interests identified in the previous Appeals by Anderson to the IESG and IAB, benefit. However, this benefit is improper. The ISOC has a right to have an accounting of this benefit.  While the ISOC has a right to the benefit, its value, or its proceeds,  it is of great interest but whether the assets and reputation of the ISOC have been misused to inure to the benefit of private interests. The ISOC has a right to restitution of the benefit, its value, or its proceeds so that the ISOC can disburse that to a proper purpose.
Article VIII. Appeal Process Followed
The IESG writes in Section 2:
This appeal asks the IESG to annul the grow WG Chair’s decision that the draft was ready for IETF Last Call, on the grounds that technical issues raised in the WG by Mr Anderson remain open.
On a point of detail, a WG Chair cannot take this decision.
The decision by the WG Chair was that the WG had reached
rough consensus to request publication.
In fact, Anderson writes in the Appeal:
The IESG should annul the decision by GROW WG Chair Geoff Huston to assert that the document draft-ietf-grow-anycast was ready for Last Call, as there were 6 un-addressed issues listed by Anderson on December 2, 2005. There is no comment on the new draft that was issued January 27, 2006 to indicate consensus. Also the Chair made an incorrect technical choice, since the subject matter of the document doesn’t work, as outlined by Anderson, previously.
While the term “ready for Last Cast” may be somewhat general, it is difficult to see this as anything but an inclusion of the chain of several improper decisions and actions that followed from the improper consensus judgment to the current state of the Document. This is clarified by the discussion on the IETF email list.
Second, in the Appeal, Anderson cites 3 issues sufficient to demonstrate that there was no rough consensus to observe:
(1) “there were 6 un-addressed issues listed by Anderson on December 2, 2005”
(2) “There is no comment on the new draft that was issued January 27, 2006 to indicate consensus”
(3) “the Chair made an incorrect technical choice, since the subject matter of the document doesn’t work, as outlined by Anderson, previously.”
The IESG uses the term “IETF Last Call” which is distinct from a Working Group Last Call. The result of an observation of consensus by a WG Chair is to change the document state to “IETF Last Call Requested”, notice of which was issued on June 2, 2006 by the IESG Secretary. The distinction evidences that the IESG is fully aware of the chain of events that are disputed, and that the first event is the improper decision of “rough consensus”.
Similarly, the IESG writes in Section 2:
“We note that such a dispute should, according to RFC 2026, be raised first with the WG Chair, and second with the Area Director, before being brought to the IESG.”
In fact, during discussion with the IESG, and before the Amended Appeal was submitted, Geoff Huston, WG Chair considered and rejected the Appeal as a WG Appeal. So, the issue was raised with the WG Chair, and rejected. The Area Director also tried to suppress the discussion, so the issue was raised with the Area Director. Further, the Appeal disputes claims made by the Area Director to the IESG; and the Appeal seeks the redress of misconduct by the Area Director Kessens. The IESG email list (email@example.com) record  demonstrates that Anderson did discuss the matter with the WG Chair and Area Director, contrary to the IESG statement. The IESG statement above is a fraudulent misrepresentation made with utter disregard to the truth.
Section 8.01 Fraudulent Misrepresentation and False Report
As stated in Section 4.02 , the IESG has a lawful duty to give information relevant to the ISOC management. The above untruthful IESG statement is a fraudulent misrepresentation and defamatory false report by the IESG with intent that superior management, the ISOC, and to the Membership of the ISOC rely on it.
Current and previous conduct by Kessens demonstrates the futility of discussing the issue of Kessens affirmative misrepresentations with Kessens. But in fact, the subject was discussed with Kessens in spite of objections by Anderson  .
The IESG writes in Section 2:
We note that the IETF process does not require unanimous consensus and does not require all technical issues to be resolved to the satisfaction of the individual who raised them. On the contrary, the IETF process recognizes that in many cases, only a rough consensus may be found.
In order to observe rough consensus, the document must be discussed; there must be something to observe indicating consensus. No such events occurred to give rise to a reasonable observation of “rough consensus”, which is prerequisite to the state of IETF “Last Call Requested”. The necessary prerequisites to a standards action have not been met, exactly the grounds described in RFC 2026 § 6.5.2
The current document stage at the time of the Appeal is “[IETF] In Last Call”. It rapidly reached this state after an affirmative misrepresentation of consensus by the WG Chair Huston. The state has passed from the Working Group, to the IESG. There would be little point in making an Appeal to the WG or to the Area Director, especially given that both are known to be seeking to cover-up and bury the complaint. It is therefore appropriate to Appeal this matter to the IESG.
Article IX. Defective WG Chair Decision on Last Call
The IESG writes in Section 2:
“We find that Mr Anderson’s issues were contributed to the WG but found little support there, so we see no defect in the WG Chair’s rough consensus decision”
The Chair’s decision is defective because it is unreasonable to conclude that a new consensus was achieved 6 months after a failed last call, especially where there has been no further discussion, and no new last call. There is no honest basis for the observation of consensus. The assertion by the WG Chair of observation of consensus in the total absence of discussion over a long period of time is a fraudulent misrepresentation and a false report to, inter alia, superior management.
Proper consideration of the WG Last Call requires that one must first consider if there been a contemporaneous expression of consensus, even a disputed expression. Because there was no discussion between December 2005 and June 2006, there was nothing to observe, and therefore there is no expression of consensus. Also, the lack of discussion means that the issues raised by Mr. Anderson in December 2005, and subsequent discoveries reported in March 2006 are never considered by the GROW Working Group. The assertion that “Anderson’s issues were contributed to the WG” is an affirmative misrepresentation made with intent that, inter alia, superior management rely on it.
Section 9.01 Deception by Kessens
In fact, the Appeal complains of Area Director David Kessens’ false assertion that Anderson was the “sole dissenter”. The IESG was given good and sufficient evidence in the Appeal that demonstrates dissent by persons besides Anderson. There are few comments on the Document from its introduction in November 2004 and little traffic in the GROW WG, so it is implausible that Kessens could have somehow missed the other dissents. As described in Section 5.01 , Kessens also has knowledge of Anderson’s position, which Kessens also affirmatively misrepresents. In determining the intent of Kessens to mislead, his entire conduct in this matter must be considered, particularly his efforts to suppress discussion of the subject. The “sole dissenter” false claim by Kessens in the Datatracker and other false claims by Kessens (noted in the Appeal) are a pattern of affirmative misrepresentations and deceit, made with the intent that others rely on the false statements.
In fact, as documented, after disputing the consensus in early December 2005, there is no further WG discussion, other than a new draft published on January 27th, 2006. There was no discussion of the January version at all. After the discovery that the scientific basis for the technology was fraudulent in March 2006, there was very little interest in stateful Anycast. There was no reason in June 2006 to consider the technology stable, much less reason to conclude that there was a consensus. These events are inconsistent with the description written by Kessens in the Datatracker Questionnaire.  Particularly, Anderson’s views are grossly misrepresented in the Questionnaire. There is no mention of the Karrenberg Fraud reported to the IESG in March 2006.
The most notable thing about the GROW Working Group is the lack of participation. The agreement of a very few persons is hardly a solid consensus. As demonstrated in the Appeal to the IESG, about a third of the participants did not approve by December 2005. Yet Kessens reported that Anderson was the sole dissenter. After December 2005, no person posted approving comments, nor were any comments whatsoever relating to the draft between December 2005 and June 2006. The January 27, 2006 announcement of a new draft version is not an approval. There is no discussion in which to observe a WG consensus in the months prior to June 2006, and the so therefore, June observation of consensus is a affirmative misrepresentation with intent that others rely thereon: a fraudulent misrepesentation and deception.
Section 9.02 Deception Central
There are several deceptions noted in the Appeal:
Deception of Consensus Observation
Deception in DataTracker Comments
Deception in Karrenberg Paper
There are also frantic efforts by Kessens to halt discussion of the Appeal, This effort is recorded  on the IESG list and on the GROW WG list. There is deception in the efforts by Kessens et al to halt and prevent discussion of stateful Anycast in other forums where the subject is relevant. There is deception in the false claims of disruption made against Anderson regarding discussion of the topic in other IETF forums.
Section 9.03 Inconsistent Statements and Actions; Deceit
The IESG published the present response on July 10, 2006 asserting there was no defect in the June WG Last Call Decision. But on July 12th, 2006, the GROW WG Chair announced a WG Last Call lasting for two weeks, soliciting comment and indication of consensus. After two weeks, on July 26th, the WG Chair reported that he “observed consensus” and subsequently requested that the document be published. Notwithstanding other defects, the proper procedure was followed in July. The bright contrast between June and July demonstrates that the proper procedure was not followed in June, and that it was impossible to have observed consensus in June. The evidence of the correct WG Last Call process conducted in July conflicts with the IESG affirmation that there was a proper process in June. This conflict demonstrates deceit in the statement of the IESG regarding Anderson’s complaint about the procedure and consensus in June.
Section 9.04 Estoppel to assert Consensus in December 2005
During discussion with the IESG, Working Group Chair Huston asserted that there was consensus in November 2005. The Appeal asserts that events that contradict this claim:
There are false statements in the November 22nd, 2005 statement by Huston
There were unresolved problems cited by Anderson in December 2nd.
There was no state change to “Last Call Requested” in December 2005.
In December, the state is instead changed to “AD is watching::Revised ID Needed”
A new draft was issued in January 2006.
The January draft was not discussed.
These events are only consistent with there being no consensus for publication of that document. However, if one were to consider for sake of argument that Huston is actually correct in asserting a consensus in December, then the events just cited in the Appeal are a misrepresentation of the status of the document. Persons including Anderson relied on this apparent misrepresentation. Huston knew of the events, knew that persons would rely on them as indications of the status of the document, but also knew of the inconsistency with (arguendo) the actual consensus. Huston allowed people to rely on that misrepresentation, and did nothing to correct it. The ISOC should therefore be estopped from asserting an actual consensus in December 2005.
Section 9.05 GROW WG Ignorant of Scientific Fraud in June.
The IESG statement that “Anderson’s issues were contributed to the WG” is also inconsistent with the facts known to the IESG in June 2006. The IESG is aware that during the important period between December 2005 and June 2006, scientific fraud was discovered and reported to the IESG, but that this report was not made to the GROW WG. The statement by the IESG “Anderson’s issues were contributed to the [Working Group]” is unreasonable and made with utter disregard for the truth.
Section 9.06 Dubious July Last Call
There remain defects in the “consensus” claimed in July. The July Last Call contrasts distinctly with the June Last Call. While the July “consensus” is procedurally correct and it can be asserted that an observation was made, there are still defects: Nine people (including Anderson) participated in July. Only three of those people had ever previously participated in the GROW WG. Only two people (Anderson and Savola) previously participated in the Anycast Document discussion. The remaining six of the participants have never previously participated in the GROW WG: (Matt Pounsett, Timothy McGinnis (McTim), William F. Maton Sotomayor, Mans Nilsson, Bill Woodcock, Stephane Bortzmeyer) Many of these are associated with RIPE-NCC or with ISC. There is a certain element of false “staging” to the July Last Call. This appears to be a breakdown in process. The July Last Call is not the subject of this Appeal, however, the IAB is now on notice of misconduct and has a duty of inquiry to investigate that matter.
Article X. Conflict of Interest of IESG Members
The IESG writes in its response in Section 3:
“The appeal makes allegations against two members of the IESG. The IESG finds these allegations untrue.”
The allegations are that Brian Carpenter and David Kessens have a conflict of interest in these matters. The IESG has been previously given notice of conflicts of interest by Brian Carpenter and David Kessens in a previous Appeal to the IESG, and subsequently in an Appeal to the IAB. The IESG and the IAB have been notified of the conflicting and adverse interests, and provided with good and sufficent evidence of the allegations. The evidence of their conflict of interest has not been impeached, questioned, explained, nor contradicted. Indeed, the IESG and IAB have seemed to take great pains to avoid discussing or investigating the matter, other than to make conclusory denials of having conflict of interest and false denials of having received evidence to support allegations. Neither the IESG nor the IAB has documented any investigation into the issues previously raised by Anderson. The lack of documentation is unusual for management boards that produces reports and analysis as part of its day to day activities. Neither the IESG nor the IAB has posed any questions to Anderson of the evidence presented, nor issued any explanation of the evidence presented, nor offered any contradictory evidence. A “finding” cannot be made without an investigation, so the claim of a “finding” is a misrepresentation of the facts, and a fraudulent misrepresentation of the IESG efforts to investigate the issues.
Supposing, for the sake of argument that the IESG has no notice of these conflicting and adverse interests, there is a duty of the employees not to engage in such transactions without permission. 
The IESG writes in its response in Section 3:
“The appeal also suggests that these two members of the IESG should recuse themselves. Mr Anderson appears to believe that if IESG members are involved in the discussion, participate in the process according to their roles, or are named in an unsubstantiated allegation, this automatically disqualifies them from considering an appeal. The IESG does not share this view, and there were no recusals.”
This is another misrepresentation of the assertions made by Anderson to the IESG and to the IAB. Anderson asserted that Kessens and Carpenter should recuse themselves because of their adverse and conflicts of interests. Business ethics and the Law of Agency require this.  The allegations of conflicting personal interests and adverse interests are not “unsubstantiated”.
Section 10.01 Notice of Evidence Substantiating Allegations Given
A definition: Substantiate.  To establish the existence or truth of, by true or competent evidence, or to verify. See Burden of Proof.
The term “unsubstantiated” means that no evidence was given, or that there was some reasonable doubt raised concerning the existence of a fact. No such dispute or doubt concerning the evidence was raised.
Section 10.02 False Report of Unsubstantiated Allegations
The IESG has made another false statement that allegations regarding the conflict of interests are unsubstantiated. The IESG was notified of good and sufficient evidence to substantiate the allegations,  but the IESG affirmatively misrepresents the evidence received, with intent that other rely on the misrepresentation.
Section 10.03 Conflict of Interest
The evidence given in the Appeals to the IAB and IESG by Anderson shows that Carpenter and Kessens have personal and adverse interests, in transactions involving their principal (ISOC) and Anderson, that are adverse and conflicting to the interests of the ISOC and Anderson. Although apparently authorized and acting within the scope of employment, neither Carpenter nor Kessens has asserted or demonstrated consent by the ISOC to deal with the ISOC as an adverse party or as a party with conflicting interests.
No member of the IESG has asserted a permission to act by or for conflicting personal interests or by or for adverse interests. Indeed, the position of the IESG is that no evidence of conflicting or adverse interest has been given. Of course, the burden is on the IESG members to fully disclose such conflicting and adverse interests, or recuse themselves. The burden is on the agent/employee to show that he has fulfilled the duties required. 
Section 10.04 Conflict of Interest: Carpenter and Kessens; Collusion
As previously documented in Appeals to the IESG and IAB, the notion of stateful Anycast is promulgated primarily by RIPE-NCC and ISC. Joe Abley authored the draft-ietf-grow-anycast Document while employed by ISC. Besides acting as Chairman of the ISOC Board of Trustees, Karrenberg is Chief Scientist at RIPE-NCC in charge of Anycast. The Appeals to the IESG and IAB gave notice to evidence of several personal connections between RIPE-NCC, ISC, Karrenberg, and Kessens and personal hostility of Kessens to Anderson. The Appeals to the IESG and IAB also gave notice of several personal connections between ISC, SORBS, Karrenberg, and Carpenter, and personal hostility of Carpenter to Anderson. The Appeals to the IESG and IAB also gave notice of collusion between Carpenter, Crocker, and others.
Section 10.05 Conflict of Interest: WG Chair Huston
We note also here that GROW WG Chair Geoff Huston is also employed by APNIC, which was the very first customer of the ISC DNS Anycast service.  Huston also has a conflict of interest on the subject of stateful Anycast.
Section 10.06 Misstatements of Adverse Party and Unfair Dealing
There appears to be no reason to consider that anyone on the IAB or IESG has been given consent to act for or with conflicting interest or adverse interests. Without consent, the employees have a duty to their principal that bars them from acting for or with such conflicting or adverse interests.
Supposing for sake of argument that consent has been given to act as an Adverse Party or with conflicting interests, there are still requirements that must be met:
Restatement of Agency § 390. Acting as Adverse Party with Principal’s Consent. Comment a:
… Before dealing with the principal on his own account, however, an agent has a duty, not only to make no misstatements of fact, but also to disclose to the principal all relevant facts fully and completely. A fact is relevant if it is one which the agent should realize would be likely to affect the judgment of the principal in giving his consent to the agent to enter into the particular transaction on the specified terms. …
Should consent have been given to Carpenter and Kessens, they would still have a lawful duty to make no misstatements of fact, to disclose all facts fully and completely, and to act fairly. Such misstatements of fact have been made as detailed in the previous related Appeals by Anderson to the IAB and IESG and in this Appeal. In denying conflict of interest, Carpenter and Kessens have not disclosed the facts fully and completely to the principal.
Section 10.07 Improvident Bargain for ISOC
Knowingly associating the reputation of the ISOC with fraudulent research is an improvident bargain for the ISOC. ISC and RIPE-NCC obtain improper benefits in greater sales from the ISOC endorsement of the stateful Anycast DNS Servers to ISPs, but the ISOC has offered its reputation as assurance. Kessen and Carpenter et al, have also improvidently and with utter disregard to the rights of others, possibly accrued torts against the ISOC through false and defamatory statements and other tortious actions in the scope of their employment. In obtaining an improvident bargain for the ISOC, Carpenter and Kessens and their conspiring or negligent associates, have not acted fairly.
Section 10.08 Fiduciary Duties to ISOC
An employee “servant” agent, has a fiduciary duty to the principal.  Kessens and Carpenter are the employees with management responsibilities, and the ISOC is the “master” and principal. The evidence of conflicts of interest stated in the Appeals to the IESG and IAB are good and sufficient evidence that Carpenter and Kessens are not disinterested, and are not performing their fiduciary duties to the ISOC.
The actions of Carpenter and Kessens are also unfair because, in violation of their fiduciary duties, they have used their influence to persuade the ISOC to agree to an improvident bargain for the ISOC: promoting a scientific fraud and defaming and disparaging Anderson,  for the benefit of ISC and RIPE-NCC, assuring customers of ISC and RIPE-NCC that stateful Anycast technology is stable, thereby promoting the sales of stateful Root DNS Anycast services.
Article XI. Call for Investigation
The IESG writes in Section 4:
“The appeal refers to “other inappropriate or unethical activities,” which is too vague for the IESG to consider.”
Anderson wrote in Section 4 of the Amended Appeal (emphasis added):
The IESG should take appropriate action with respect to other inappropriate or unethical activities that are brought to light as a result of investigation, including unethical or inappropriate attempts to influence or interfere in this or other proceedings.
The IESG takes the most obtuse view and misrepresents what has been requested. The IESG board members, as delegated managers, are under a duty of care and a duty to inquire. The refusal to perform these duties is part of a larger pattern of conduct seeking to cover-up misconduct and asserts a frivolous reason not to investigate the allegations.
Article XII. False Report of Disruptive Misconduct
The IESG writes in Section 5:
“On an additional matter not mentioned explicitly in the appeal, the IESG notes that the AD and WG Chairs considered that Mr Anderson’s allegations of fraud on the WG list were fundamentally wrong and irrelevant and thus disruptive; this is not a matter where the IESG intends to overrule the AD’s and WG Chairs’ judgement. This does not imply that statements or questions about incorrect data are inappropriate when those data are being directly considered by the WG. As noted above, the IESG would take substantiated usage of incorrect or fraudulent data within the IETF very seriously.”
Section 12.01 False Report of “fundamentally wrong” allegations
It was previously shown in Section 5.02 and Section 10.02 that the IESG has falsely stated that no evidence was given regarding fraudulent data. Even without notification of evidence, the IESG has a duty to inquire and investigate the allegations. Yet, the IESG has asserted no basis to dispute these allegations, but merely denied receiving notification of evidence. The IESG has not documented any investigation into the allegations to support its asserted “finding”, despite the requirements of “fair and open process” and its superior abilities to conduct and document and investigation. The IESG has offered conclusory statements of dispute, but has conducted no investigation, and has no basis whatsoever to assert that Anderson’s allegations are wrong. But as shown in those Sections, Anderson in fact gave good and sufficient evidence of fraudulent data. The assertion that the IESG has not been notified of good and sufficient evidence is an affirmative misrepresentation with intent that others rely thereon. So the assertion by the IESG that the allegations by Anderson are “fundamentally wrong” is also an affirmative misrepresentation and defamatory false report with intent that others rely thereon.
Section 12.02 Relevance of Allegations to GROW WG Document
The draft-ietf-grow-anycast Document is premised on the notion of achieving stateful Anycast. So the stability of stateful Anycast is relevant to the Document. Evidence presented by Anderson demonstrates that Karrenberg falsified conclusions in a published report about the stability of stateful Anycast. Because the stability of stateful Anycast is relevant to the GROW Document, and the report concerns the stability of stateful Anycast, the report is therefore relevant to the quality and integrity of the GROW WG draft-ietf-grow-anycast Document. The logic of the relevance is sufficient to any person of ordinary experience and intelligence such that the IESG board members should have inter se. 
Section 12.03 Actual Evidence of Fraud Unnecessary for Relevance of Allegations
If, for the sake of argument, it were the case that allegations were made without supporting evidence, the allegations are related to the subject of stability of stateful Anycast; a subject which is relevant to the quality and integrity of the GROW WG Document. So the discussion of those allegations is also relevant to the GROW WG Document subject matter even if it were subsequently found that no evidence existed to support the allegations. The IESG and WG Chair’s assertion of irrelevance in the allegations is therefore unreasonable. The statement is an attempt to cover-up the reported scientific fraud. The assertion of irrelevance is also a misrepresentation of facts and knowledge that the IESG board members have inter se and a false report to superior management, the ISOC Board of Trustees, and to the Membership of the ISOC.
But in fact, the IESG was also given notice of good and sufficient evidence of scientific fraud, so the refusal to consider the allegations is itself indication that the IESG board members are not actuated by their duties to the ISOC Corporation, but actuated by adverse and conflicting interests.
Section 12.04 False Report of Disruptive Activity
We reassert that reporting relevant allegations, supporting evidence, and initiating an Appeal is not “disruptive” by any reasonable standard. Within the context of the ISOC business, Anderson’s statements and conduct are proper, permitted, and appropriate exercise of speech. Anderson’s speech and conduct is in accordance with ISOC and IETF rules, and in accordance with public policy and public interest to promote credible scientific research and standardization. No persons were prevented from speaking by Anderson’s acts, nor was any employee, agent or independent contractor of the ISOC prevented from performing their duty by Anderson’s conduct. No regular operation of the ISOC or of any IETF activity, or of the GROW WG was impeded by Anderson’s activity. Anderson’s speech and conduct were properly conducted under the rules of the ISOC and IETF activity and the GROW WG charter. The IESG assertion of disruption is an affirmative fraudulent misrepresentation and defamatory false report made in bad faith to superior management, the ISOC Board of Directors and the membership.
Section 12.05 Pattern of False Reports
This is not the first time that adversely or personally interested IAB and IESG board members and certain WG Chairpersons have made a false report of disruption by Anderson. Previous defamatory false reports have been made on the subject of the instant scientific fraud and also by ISOC Employees acting to personally or adversely promote the interests of ISC and SORBS. The instant false report is part of a pattern of defamatory false statements.
A great deal of good and sufficent evidence has been given revealing the adverse and conflicting interests of Brian Carpenter and David Kessens in previous appeals to the IESG and IAB. This evidence has not been questioned, contradicted, or explained.
Section 12.06 Improper Motive Actuating Conduct
Kessens and Carpenter have sought to promote their own interests and the interests of adverse parties:
to give approval to a dubious notion of stateful Anycast benefiting their associates, particularly sales of stateful DNS Root Anycast servers promoted by ISC, RIPE-NCC, Verisign, et al, and
to give approval to dubious anti-spam methods and organizations also benefiting their associates, particularly Brandenburg Consulting, and
Patented DNS encryption cover-up, benefiting an undisclosed Patent holder.
Kessens and Carpenter have also sought the effect and goal of defaming, disparaging, and discrediting Anderson because he has blown the whistle on these improper activities and the improper activities of their associates.
Section 12.07 Bad Faith of IESG: Complaint Process not “Disruptive”
Authorities have held that a member’s good faith participation in a civil suit against a non-profit corporation is not grounds for expulsion.  . On Appeal, the Court writes in Malibou Lake Mountain Club v. Robertson: “Malibou Lake Mountain Club sought to expel one of its members for misconduct. The court held the purported expulsion not to be in good faith and declared the member still to be in good standing.” Anderson asserts that a member’s good faith participation in remedies within the organization is also not proper grounds for expulsion, especially when the expulsion is in bad faith, with an improper object. In Malibou Lake Mountain Club v. Robertson the club similarly asserted that the suit by the member “disturbed the peace and tranquility of the Club”. The Court writes: “The prosecution, in good faith, of a legal right for redress, even if unsuccessful, is not a ground for expulsion from an organization such as this.” Similarly, the instant Appeal is not disruptive and the statement by the IESG is a defamatory false report of misconduct made in bad faith.
 Available at http://www.av8.net/IETF-watch/IESG/Appeal-draft-ietf-grow-anycast.html
 Available at http://www.ietf.org/IESG/APPEALS/appeal-response-deananderson-lc-draft-ietf-grow-anycast.txt
 Available at http://www.iab.org/appeals/2006-07-13-anderson-response.html
 Available at http://www.iab.org/appeals/2006-04-18-anderson-appeal.html
 See http://www.av8.net/IETF-watch/IESG/Appeal-draft-ietf-grow-anycast.html#hustonwgappeal
 See http://www.av8.net/IETF-watch/IESG/Appeal-draft-ietf-grow-anycast.html#hartmanappealconfrontational
 Available at http://www.av8.net/IETF-watch/IESG/Appeal-draft-ietf-grow-anycast.html
 See http://www.av8.net/IETF-watch/IESG/Appeal-draft-ietf-grow-anycast.html#hartmanappealconfrontational
 See Restatement of Agency 2d, §§ 381, 389-392, 394. Duties of Service and Obedience, Duties of Loyalty
 See Id. §§ 379, 381-383, 385, 387-394.
 See Id. §§ 389-392, 394.
 See RFC 2026 § 1; See “All About the Internet Society” available at http://www.isoc.org/isoc/
 See RFC 3710, An IESG Charter
 See Restatement of Agency 2d, § 381. Duty to Give Information
 See Id. § 381. Particularly comment a. and d.
 Available at http://www.isoc.org/ Click on “All About ISOC”, then click on “ISOC Principles and Goals”. On the bottom half under “Purposes and Goals of the Organization” see particularly sections d), f), and h).
 Black’s Law Dictionary 458 (Abridged Sixth Edition 1991)
 See PR-Action available at http://www1.ietf.org/mail-archive/web/ietf/current/msg38293.html
 See RFC 3710, An IESG Charter at § 3.1
 See Restatement of Agency 2d, § 399. Remedies of Principal
 See Id. § 403. Liability for Things Received in Violation of Duty of Loyalty
 Available at http://www.av8.net/IETF-watch/IESG/Appeal-draft-ietf-grow-anycast.html
 See Id. Particularly messages from Kessens.
 Available at http://datatracker.ietf.org/ Enter draft-ietf-grow-anycast into Filename field and click “Search”. Click on “Detail”, scroll to comment posted 6/5/06 by dinaras. Click “View Detail”.
 See Id.
 See Restatement of Agency 2d § 236, 389, 394
 See Id. §§ 387-394
 Black’s Law Dictionary 997 (Abridged Sixth Edition 1991)
 See Appeal to IESG at http://www.ietf.org/IESG/APPEALS/Anderson-appeal-03-08-2006.htm, and Appeal to IAB at http://www.iab.org/appeals/2006-04-18-anderson-appeal.html, and see Appeal to the IESG at http://www.ietf.org/IESG/APPEALS/appeal-draft-ietf-grow-anycast.txt
 See Restatement of Agency 2d, § 389 comment d.
 Go to http://www.isc.org/, click on “About ISC”, click on “Press Room”, click on “more…”, scroll to 2002-11-17, click on ISC expands DNS ”Root Server” Footprint; ISC and APNIC Launch ”F-root” Services in the Asia Pacific
 See Restatement of Agency 2d, § 13. Especially comment a: “Among the agent’s fiduciary duties to the principal is […], the duty not to act as, or on account of, an adverse party without the principal’s consent, […]”
 See Id.§ 390. Especially comment c: “Fairness. The agent must not take advantage of his position to persuade the principal into making a hard or improvident bargain.”
 See Id. § 10. Knowledge Which Principal or Agent Should Have Inter Se
 18A Am. Jur, 2d, Corporations § 778 (2004); see also Malibou Lake Mountain Club, Limited v. Robertson, 219 Cal. App. 2d 181, 33 Cal. Rptr. 74 (2d Dist. 1963)