[ppml] FW: No transfer policies are needed

Edward Lewis Ed.Lewis at neustar.biz
Tue Apr 22 15:19:08 EDT 2008

I have not worked for an ISP/LIR and haven't managed address 
assignments.  So I want to ask some questions related to the 
"reality" of this scenario.

At 11:40 -0700 4/22/08, Ted Mittelstaedt wrote:

>In other words, suppose you have a small ISP "SmallCo Inc." that
>owns an IPv4 block it doesen't need.

In that case, isn't ARIN justified in recalling the block?  Or is 
this a block that is "legacy?"

The context of my question is that I have long assumed that the issue 
with the markets is the large amount of legacy (=RIR unencumbered 
space) and not the space covered by registration service agreements.

>You have an ISP named "MCI Corp" that needs more IPv4 and does
>not meet the utilization criteria to get it from ARIN
>SmallCo secretly sells it's block to MCI Corp.

How is this different than reassigning or reallocating addresses from 
SmallCo to MCI?  Instead of selling the addresses as capital, why 
don't they just record a charge (= to an amortization "cost" - 
remember, I'm not an economist), a "rental" of the addresses?

>SmallCo sends a name-change in to ARIN claiming it's spinning off it's
>ISP operations to a separate company named "NewCo Inc"  ARIN changes the
>record on the block.
>MCI Corp then registers the company name "NewCo Inc" as a subsidiary
>of MCI Corp. in whatever state it's incorporated in.

This seems like a lot of trouble to accomplish what an 
upstream/downstream relationship already is.  If I understand that 

>Another "black market" scenario would be for a large org that did not
>meet utilization criteria to create an independent company, use that
>company to obtain a block from ARIN, then "buy" that independent company.
>Of course, that only works before IPv4 runout.

My problem is that I find it hard to imagine that a large 
organization could not meet the utilization criteria (in a way 
cheaper than having to incorporate and buy a new company).  I could 
understand these scenarios after the free pool runs out and that is 
the reason that the large organization failed to get space.

>I am not familiar enough with the existing language of the various RSA's
>that the RIR's use to know if such behaviour is explicitly prohibited but
>I think it is, certainly it violates the intent.

My read of the scenarios is that these seem like a lot of work to 
circumvent the rules when there's gotta be something else that was 
missed.  Maybe these scenarios are close to what's happening, or 
could happen, but I don't see that the scenarios are realistic.

>In any case, I would assume that ARIN would have the guts to revoke
>assignments on any blocks that were transferred in this manner, if it
>discovered them.  Thus, I think the risks of block revocation would likely
>make an "IPv4 black market" a non-starter.

I can imagine that the one wanting the space might not get what they 
want, but if someone has space available, that's space ARIN could 
revoke, no?

>The typical MO of the EPA when it discovers a polluter, is to tell the
>polluter that if they spend the money to install pollution control that
>they will only get a token fine and nobody will go to jail.

The limitation of this analogy is that there's no widespread cost to 
clean up when a block of addresses has been "hoarded."  Unless you 
stretch this to include router slots or something.  Addresses held 
back represent growth that isn't happening but once they are 
reclaimed, the damage is instantly undone.

I don't mean to argue. I'm just not following...
Edward Lewis                                                +1-571-434-5468

Never confuse activity with progress.  Activity pays more.

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