[arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

[Owen DeLong]

On May 11, 2011, at 8:09 PM, Mike Burns wrote:

> Hi Jon,
>  
> Here are some examples of an entity that may want to purchase addresses but not demonstrate need:
>  
> 1. A company with a 5 year planning horizon

That company probably wanted to get more address space from the free pool, too.
I fail to see a meaningful difference.

> 2. A company that wants to provide temporary allocations

I suspect I could produce a justified need that would pass muster for such a business.

> 3. A company that wants to specialize in very rapid allocations, like same-day service.

We call those "ISPs" and they are able to provide justified need under policy today, so, I'm
not sure why you figure this would be different going forward.

> 4. A company that stocks addresses for sale in to those who would pay more for guaranteed availability

I believe providing for such companies to the detriment of other organizations with more
immediate need is contrary to the interests of the community and represents one of the
many good reasons for preserving needs-basis in transfer policy.

> 5. A company who is concerned about future supply.

Vs. everyone else who doesn't care? Get real.

> 6. A company that wishes to lease address space rather than sell it

This could be answered either with my answer to number 3 (lease with network services) or
my answer to number 4 (lease without network services).

> 7. A company who seeks to buy up small allocations to aggregate them in to larger, more valuable netblocks

The end recipient can do this just as effectively and has justified need. The community receives
no benefit from this middleman.

> 8. A seller of vanity ip addresses like 100.100.100.100

See answer number 4.

> 9. A speculator willing to risk money to buy addresses as an investment for anticipated gains in address prices.

See answer number 4.

> 10. A company whose anticipated need does not begin for 12 months.

See answer number 4.

>  
> I'm sure there are many more that I cannot think of. I agree with you that most buyers will have need, and I agree with you that most buyers will see the value of maintaining a valid ARIN whois record pointing to their authority.
>  
> But the policy in APNIC was changed to remove needs requirements for transfers for the same reasons I am requesting its removal here.
> My policy proposal also has the benefit of incentivizing legacy resources to come under RSA, and it serves to even the playing field between the disparate rights of legacy versus non-legacy holders.

This is not entirely accurate. The transfer policy in APNIC was created without needs basis. It was not modified to remove it.

Rendering the RSA mostly moot in order to incentivize legacy holders to sign it is not a win IMHO.

>  
> And my underlying point is the obvious one, that the very act of paying for address space is a very good indication of need, or at least perceived need on the part of the buyer.

Which is an assertion that makes me shake my head in dismay.

There are many many reasons to pay for address space outside of need. $LARGE_TELCO may want to make life
hard for all the independent Telcos and other smaller competitors in their service region. By purchasing very
large amounts of address space and then reselling it at a premium, or, worse, merely keeping it, they can
parlay their better capitalization into a serious anti-competitive act.

Owen

>  
> Regards,
> Mike
>  
>  
>  
>  
> ----- Original Message -----
> From: Jonathan Fernatt
> To: Mike Burns
> Cc: arin-ppml at arin.net
> Sent: Wednesday, May 11, 2011 10:55 PM
> Subject: Re: [arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate
> 
> 
> What is the great benefit that outweighs the danger to Whois of unbooked transfers and the benefits of incentivizing legacy resources to come under RSA?
> Who says my proposal would result in completely unregulated markets? Every transferee would sign an RSA and be subject to ARIN policy.
> And with my policy or without my policy, addresses are bound to flow to the highest bidder.
> If the policy proposal doesn't fly, it will be to the highest bidder who can show need.
> Do you think that we should take more steps to protect the little guy in this event?
> Maybe a price cap? An address czar?
>  
> 
> I keep seeing seeing this argument from you Mike. I honestly can't understand why you think the needs requirement is such an obstacle for a company with a legitimate need for addresses that they would have to avoid ARIN altogether. Following that same train of thought, wouldn't it be easier for a company who didn't care about the process or being honest to just falsify their needs justification?
> 
> I deal with tiny tiny tiny companies who have had no problem whatsoever showing need for resources. ARIN staff and policy have always seemed very accommodating from my perspective. 
> 
> Have you had a different experience?
> 
> Jon
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