[arin-ppml] ARIN-prop-145 STLS Listing Immunity

[Matthew Kaufman]

On May 2, 2011, at 11:50 AM, Scott Leibrand wrote:

> On Mon, May 2, 2011 at 10:59 AM, ARIN <info at arin.net> wrote:
> ARIN-prop-145 STLS Listing Immunity
> 
> <snip>
>  
> Add a subsection to Section 12 (Resource Review) of the NRPM:
> 
> ARIN may not revoke any resources issued by ARIN that are presently
> listed as "available" on the ARIN Specified Transfer Listing Service
> unless there is sufficient reason to believe that the holder does not in
> fact intend to transfer these resources.
> 
> Another way to accomplish this would be with the following language from the original transfer policy proposal, 2008-2:
> 
> The fact that an IPv4 address holder is making IPv4 addresses available for transfer, pursuant to this policy, does not, in and of itself, indicate that the address holder lacks the need required for an allocation under ARIN policy.

Sounds like it accomplishes basically the same thing, yes. (Only see below)
> 
>  
> 
> Rationale:
> 
> An entity may list space as available and might begin the process of
> moving out of that space in order to facilitate the transfer. A review
> after such work was in progress might reveal that the addresses are not
> sufficiently utilized.
> 
> Additionally, because posting a listing on the STLS signals directly to
> ARIN that an entity believes it can use addresses more efficiently, ARIN
> might simply use STLS listings in order to trigger audit under 12.2(c).
> This would not be fair. (And would be a disincentive to using the ARIN
> STLS at all in order to list available space)
> 
> I believe that ARIN has made assurances that this will not be done, but I would support such assurances into policy as well if people think it's needed. 

I think it should be written down somewhere, preferably in a place that is changed based on community involvement (rather than simply the STLS FAQ) in order to keep people from worrying that listing their addresses might trigger an audit.

Note that this applies to all listing services, but *particularly* to STLS, as the listing on STLS is a direct statement TO ARIN that the org thinks it can use its address space more efficiently (which an indirect statement, as on eBay, or a hidden statement, as via a 3rd party soliciting bids does not)

> 
> This policy would also serve to increase the value of the ARIN STLS over
> other possible transfer listing services, increasing the transparency of
> the transfer market, particularly to ARIN, who wishes to ensure that
> transfers take place within NRPM 8.3.
> 
> 
> I think it's important to make any "Safe Harbor" statement apply to all IPv4 addresses being made available for transfer (including those on eBay etc.) not just those offered through ARIN's Specified Transfer Listing Service. ARIN has repeatedly made clear that the STLS is completely optional, which I believe is the right way to approach it.  I don't believe we should be giving the STLS preferential treatment in the transfer policy in any way.

Interesting point of debate. I wrote this to give STLS an advantage over other listing services because I believe that a single marketplace leads to a more efficient market, particularly in the case where there are so few transactions taking place.

This also plays well into the alternative idea that you'd sell them on eBay perhaps but only *after* both signaling your intent to do so to ARIN (by listing on STLS) and at the same time receiving certification that ARIN really believes the addresses are yours to transfer.

It is in ARIN's best interest to know about transactions BEFORE they take place. Granting immunity would be one of the incentives for telling ARIN directly.

Matthew Kaufman

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