[ppml] Securities Act 15 U.S.C. 77b(a)(1)

Scott Leibrand sleibrand at internap.com
Tue Mar 11 20:41:22 EDT 2008


We understand your concern, as does ARIN, the BoT, President, and 
counsel.  Thank you for raising the issue.  As others have explained, 
the way we've been asked to make policy is to first come up with the 
policy that makes the most sense for the community.  ARIN counsel will 
provide a legal assessment of each policy proposal when it comes before 
a public policy meeting.  If there are areas of particular concern, they 
will be addressed before any policy proposal is adopted by the BoT.

The legal and economic issues surrounding the IPv4 Transfer Policy 
Proposal will be also be discussed at the Denver meeting, so I think 
that would be the best forum to continue this particular discussion if 
you wish to do so.


michael.dillon at bt.com wrote:
>>    It's possible that you didn't see my response below:  We have had
>>    ARIN Counsel look into this possibility per your request, 
>> and it does
>>    not appear to be an issue.   If a specific policy proposal 
>> comes before
>>    the Board, we will seek an in-depth legal review at that time.
> What is it that isn't an issue?
> We have had at least one suggestion here that once transfers are
> allowed, ARIN should provide a listing service which quotes all
> transactions that take place in order to provide market transparency.
> I can believe that the policy proposal which simply allows transfers
> doesn't slide into the SEC regulatory area. But real-time listing
> services just like the NYSE and CBOT? Somewhere there is a line
> which we should know about so that we don't waste our time
> pushing the policy in a direction that attracts government regulation.
> The possibility of FCC regulation has been well and truly put
> behind us by work that ICANN and the DOC did, but the SEC is a different
> ballgame.
> Since we don't have a really clear case-law ruling that IP addresses are
> not property, even that could change if and when people start buying
> and selling address blocks.
> --Michael Dillon
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