[arin-ppml] Policy Question(s)

Owen DeLong owen at delong.com
Wed Oct 6 10:13:42 EDT 2010


On Oct 5, 2010, at 4:14 PM, Ronald F. Guilmette wrote:

> 
> In message <6E785560-2860-4180-8192-4B95B7308314 at arin.net>, 
> John Curran <jcurran at arin.net> wrote:
> 
>> On Oct 5, 2010, at 5:22 AM, "Ronald F. Guilmette" <rfg at tristatelogic.com> w=
>> rote:
>> 
>>> So my question remains... if _someone_ creates a brand new, fresh, newly
>>> manufactured LLC, can some other company that happens to have an unused
>>> /18 lying around just ``gift'' that /18 to this new legal entity the
>>> very next day?
>> 
>> Ron -
>> 
>>   If you believe that resources were transferred contrary to the policies=
>> as shown in the Network Resource Policy Manual, section 8 (Transfers), the=
>> n report it on the already noted ARIN Fraud reporting link and we'll invest=
>> igate and correct the Whois entries if changed contrary to community policy=
> 
> 
> Thank you John.  Believe me, despite my reservations about what you
> folks may or may not consider to be the specific types of fraud that
> you feel are within your portfolio to look into, I most certainly
> would (and will) accept your invitation, and report to you, via the form,
> anything that, as you say, looks to me to have been contrary to the policy
> as laid out in Section 8 of the NRPM.
> 
> But see, here's the problem... In this case in particular... and also
> in at least one other I'm aware of... I honestly am having trouble
> interpreting what the words... specifically in Section 8.3... actually
> mean.  Can you please give me just a tiny bit of help with that?
> 
>    8.3. Transfers to Specified Recipients
> 
>    In addition to transfers under section 8.2, IPv4 number resources within
>    the ARIN region may be released to ARIN by the authorized resource holder,
>    in whole or in part, for transfer to another specified organizational
>    recipient. 
> 
Try actually including the full passage...

8.3. Transfers to Specified Recipients

In addition to transfers under section 8.2, IPv4 number resources within the ARIN region may be released to ARIN by the authorized resource holder, in whole or in part, for transfer to another specified organizational recipient. Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources, as a single aggregate, in the exact amount which they can justify under current ARIN policies.


> This passage appears on the face of it to give you (ARIN) pretty much
> carte blanche to approve inter-company transfers as you think best,
> or not, as you think best.  (Note the use of the word "may".)  The above
> would appear to make ARIN judge, jury, and executioner for all inter-company
> and/or inter-organization transfer requests.  (Does that sound about right?
> Or am I misreading it?)
> 
That's because you left off fully half of the policy.

Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources, as a single aggregate, in the exact amount which they can justify under current ARIN policies.
The requirement for RSA and demonstrated need basically refers
back to NRPM section 4 (even though it does not spell that out).
The only mechanisms ARIN has for determining "demonstrated
need" is specified in NRPM 4 (IPv4) and NPRM 6 (IPv6).
> 
> 
> So again, this is a policy question:  May a company which is still very
> much alive and kicking request that ARIN transfer some block it owns
> to some brand new, newly manufactured company with no history whatsoever?
> Is that permissible under ARIN's discretion granted in 8.3. as set forth
> above?  And even if it is permissible for some company to _request_ such
> a transfer, is it permissible, under the policy, for ARIN to _grant_ such
> a request?   And if it is actually permissible under 8.3. to do that exact
> thing, then may *I* go forth now and start buying up blocks of ARIN region
> IP space, you know, as an investment, with equal confidence that you will
> willingly transfer any blocks that I might buy to _my_ new company, just
> as, it would appear, ARIN did in the case of 216.59.128.0/18 ?
> 
If that newly manufactured company can show demonstrated need
under NRPM 4, then, yes. If that company cannot, then, no.

Again, read ALL of 8.3 instead of just the first half and it helps a lot.
The answer to your second question is no.

Since the first and second questions are "no", then third question is
also, by extension no. Policy prohibits it unless you fit the criteria
expressed above. This has been said multiple times.

> And if the answers to all of the above questions are "no", then really,
> I would very much like to know how an 11 year old block that belonged
> to a company that is very much still alive (http://globalitcom.com/)
> ended up registered to a shadowy mystery company that has no web site
> and that, according to California Secretary of State online records,
> was only formed just late last year (i.e. orangeisp.com[1]).
> 
In separate off list email I have sent you no less than 4 possible ways
this could have occurred.

> This is only marginally a question about what policies did or did not
> allow _these companies_ to effect or to request this transfer.  It is
> really more a question about what policy or policies _ARIN_ was being
> guided by when it approved and allowed this transfer.
> 
This isn't necessarily a matter of public record, so, I don't know whether
ARIN is able to directly answer that specific question or not.

> (Note: I rather doubt that Orange County Networks, LLC sent you ARIN folks
> any fradulent documents claiming to be an 11 year old company, and even
> if they had done so, it would have been easy enough for you folks to check
> and disprove that online, in just a few seconds.  So it would appear that
> ARIN knowingly approved the transfer of an 11-year-old /18 block to what it
> knew, or could easily have known, was a brand new... albeit somewhat dubious...
> company.)
> 
Claiming to be 11 years old, probably not. Claiming to be the new successor
organization to an 11 year old company, however, is  a different matter.

Owen

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