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

John Santos JOHN at egh.com
Thu May 12 20:40:11 EDT 2011

On Thu, 12 May 2011, Mike Burns wrote:

> Ola John,
> >  I'll actually disagree with the presumption that incentives towards
> >  gaming will increase with the value of IP address space, if we are
> >  considering a transfer market with needs-based qualification.  While
> >  it is true that there might be incentive to get creative with the
> >  total expressed need to obtain more space than otherwise qualified
> >  for, the existence of a market (if properly functioning) means that
> >  there is some reassurance that additional space will more likely be
> >  available when needed in the future, even if at a slightly increased
> >  price. This actually reduces the pressure to try and game the system
> >  when compared with the present environment and potential that there
> >  will be no more resources in the free pool when you come back later.
> > The other potential form of gaming would by a non-operator speculator,
> >  who wishes to participate in the market (despite having no actual need
> >  at all), and so needs to fabricate imaginary need to be able to obtain
> >  IP space from the market for subsequent monetization.  While there is no
> >  doubt of the incentives involved, there is also significant risk since
> >  intangible IP registration entries are readily corrected in such cases
> >  of fraudulent representations to the registry.
> If the needs requirement can not be met by the buyer, he will have the 
> incentive to game the needs requirement.

Why would the buyer be unable to meet the needs requirement?  There are
two possible reasons: 1) The buyer has need but it is not being recognized
by ARIN or 2) The buyer does not have any actual need.

In the 1st case, the buyer can protest to PPML and lobby for policy
changes that allow his need to be accomodated, or complain that policy
is not being followed by ARIN staff.

In the 2nd case, too bad.

> If the value of the addresses at question are higher, the incentive will be 
> higher, to my mind.

Why did Willie Sutton rob banks?

> But you are absolutely correct in that having a vibrant and functioning 
> market is the best way to assuage fears of future supply shocks and 
> attendant price increases.
> And you are correct in that the incentive to game the system for allocations 
> from the free pool is reaching its highest point in the months to come.
> Pray be diligent!
> As far as what you term a non-operator speculator, you see the risk of 
> gaming the needs analysis.
> The same risks lead to not-notifying ARIN and continuing to use the 
> addresses under the purchaser's name, leaving Whois in more disarray.

Someone who is actually using the addresses almost certainly has need.
Maybe they have more than they need, but they do have at least some
need.  It is people who are sitting on UNUSED addresses (for reasons
of speculation, or vague fears that they will need the addresses in
the future but won't be able to acquire them, or to deprive needful
competitors of them), that are the issue.

The hope of the marketplace idea (and so far as I can see, the only
positive virtue of it) is that people who have need but more addresses
than they need, but who have to renumber to consolidate their usage
into a smaller block, will be motivated to do so if they can recoup
some or all their renumbering costs by selling their surplus addresses
on the market.

Other possible situations:  1) If they have no need at all (which
implies they aren't using any of their addresses) then there is no
cost to renumbering.  According to the RSA, or implicit in the original
application to NetSol or its predecessors (which was predicated on
need), they should return unneeded addresses.  The general consensus
seems to be that this is unenforcible on legacy holders, but I see
no reason to grant them a windfall.

2) They have approximately as many addresses as they need (including 
current use and reasonable projections for the next year or so), then 
they have no reason to participate in the market.

3) They need more addresses.  They should get them from ARIN, while
they are still available, or go to the market for them if ARIN can't

This whole thread has been suffused with constant conflating of
different situations and conditions, in many combinations that
don't actually make sense or exist in the real world.

> Regards,
> Mike

John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539

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