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

Mike Burns mike at nationwideinc.com
Fri May 20 10:26:22 EDT 2011

Hi Tom, leaving the message unsnipped,

On May 19, 2011, at 7:31 PM, Mike Burns wrote:

> >> Can you provide us with a comparable measure of the number of old 
> >> address holders who have not responded to opportunity afforded by the 
> >> 8.2 change?
> >
> > No.
> >
> >> If possible, please break down the number into two groups -- those who 
> >> are on the fence and holding out fin hopes of additional blandishments 
> >> and concessions, and those whose philosophical or >commercial 
> >> priorities preclude registration regardless of the side payments.
> >
> > I have never met anybody whose philosophical or commercial priorites 
> > preclude registration. I imagine that many of those who have not done 
> > the 8.2 transfer have failed to see any utility in doing so.
> > Besides, the ARIN language never required it, it only says "ARIN will 
> > consider requests for transfers."  And since the addresses continued to 
> > be routed without notifying ARIN of the mergers and acquisitions, many 
> > failed to apply. Also, for legacy holders, an 8.2 transfer meant having 
> > to sign an RSA, I think, which was a disincentive.
> If you are uncomfortable with the second half of of the question, then a 
> simple accounting of all of the old address holders who have not responded 
> yet will suffice.
> To quote what you deleted, for the sake of clarity:
> "I have argued that the uptick in 8.2 transfer requests is in response to 
> natural market forces at work. Prices go up and owners of address block 
> control take steps to ensure accurate registration."
> Without some means of (at minimum) benchmarking the relative size of (or 
> anything else about) that "slight uptick," your interpretation of its 
> causes and relevance are completely subjective.
> Tom, how could I have any of the information you are soliciting? I merely 
> held that I think the uptick in processing of 8.2 transfers for historical 
> mergers and acquisitions that John Curran mentioned is evidence of the 
> increasing desire to have addresses properly registered as the value of 
> those assets increases and replacement addresses are no longer available 
> from the free pool. And that was in response to your assertion that it is 
> the needs requirement which increases Whois accuracy. My point was, and 
> is, that there is a logical reason for address holders to desire 
> registration, and that they would naturally do so if not impeded by the 
> necessity of passing ARIN's needs analysis.

>Fair enough, you prefer to argue logic rather than facts:

I don't understand why you would even ask me for "facts" that nobody could 
possibly have, like "Can you provide us with a comparable measure of the 
number of old address holders who have not responded to the opportunity 
afforded by the 8.2 change" , and then "please break that number into groups 
of those who are on the fence and those whose philosophical priorites 
preclude registration."
Is that some kind of debating tool?  I think everybody here knows those 
facts would be impossible to come by without somehow listing and polling all 
address holders who my have been merged or acquired in the past, and then 
getting accurate information as to their "philosophies". Was this just to 
come around to your point that unless we can prove what the results of a 
policy change will be, the policy shall not be changed?

>Please provide a negative proof that "logic" could never lead any future 
>address user, potential address buyer, and/or potential address seller to 
>conclude that registration would not advance their own >private interests.

Who cares if somebody will conclude that they will not want to register?  My 
proposal is designed to remove disincentives toward registration.

>Please provide a negative proof that "logic" could never lead any future 
>address user, potential address buyer, and/or potential address seller to 
>embrace "sales-friendly registration" but simultaneously >reject 
>"operationally relevant registration" (i.e., the kind that makes whois an 
>appropriate subject of interest for community deliberation).

Again, you posit these nefarious types to what point? They can pull the same 
tricks with or without my proposal.

>Please provide a negative proof that "logic" will BOTH always lead all 
>future address users, address buyers, and address sellers to self-maintain 
>"operationally relevant registration" for themselves in >perpetuity, AND 
>that the attainment of that outcome by means of needs-free transfers could 
>never have any unintended consequences that might be as serious or more 
>serious than some marginal >degradation of whois accuracy.

Tom, I find it a pretty silly argument. Basically, unless I can not just 
demonstrate every consequence, even unintended consequences, of my proposal, 
but "prove" that they won't be as serious as what you, in loaded terms, 
calls marginal degradation of whois accuracy, then the proposal should be 
abandoned? If we applied the same test to any proposal, requesting proof of 
the seriousness of future unintended consequences, then nothing could be 

>> Yes,  I never held that this interpretation was more than my subjective 
>> opinion backed up by an understanding that registration is the clearest 
>> means of establishing ownnership rights to control of these >>assets, and 
>> as those rights become increasingly valuable, owners will seek accurate 
>> registration.

>So you have no actual "apples-to-apples" firsthand experience to 
>corroborate that opinion then?

How could anybody but ARIN staff have any experience in discerning the 
reason for the recent uptick in 8.2 transfer requests for historical 
mergers. I merely said such an uptick would be expected to occur as IP 
address holding rights increase in perceived value.

>Perhaps someone who anticipates the possibility of buying addresses in the 
>future but has no particular preference for registered addresses and no 
>intention of registering purchased addresses themselves >can get in touch 
>with Mike off-list?

Wow, you seem really certain such entities exist, who would want to buy ip 
addresses but not have Whois updated, or have Whois updated with semi-bogus 
information. What makes you think my proposal would have any effect on these 
mysterious entities? If they *want* to be off the books, I suppose they will 
try to be off the books. My proposal addresses those who *want* to be 
accurately registered in Whois, but who find an impediment to that in ARIN's 
needs requirements. For the record, I still have never met or heard from 
anybody who wanted to buy addresses and not be registered as the buyer, no 
such person has contacted me off-list.

> >> Having enjoyed the extremely lopsided privilege of discussing broadly 
> >> related matters with Geoff semi-regularly between the years 2000~2009, 
> >> I wholeheartedly agree that he is one of the world's >foremost experts 
> >> on BGP. However, with all due respect to the man, Geoff's views about 
> >> the relative merits of market-based vs. RIR-style need/capability-based 
> >> number resource allocation were formed >*before* BGP was widely 
> >> deployed [1]. To my knowledge, the first concrete expression of those 
> >> views took place in mid-1994, as documented for example in the recently 
> >> published 20-year >retrospective on AARNET and the early days of the 
> >> Internet in Australia [2]. The second concrete expression of those 
> >> views AFAIK is RFC 1744 (December 1994), which I (completely 
> >> subjectively) >interpret as a somewhat bitter personal reflection on 
> >> the results of the first experience [3].
> >
> >> Regardless of whether or not that interpretation is valid, 
> >> contemporaneous Australian press accounts indicate that AARNet's 
> >> acquisition by Telstra was announced on January 7 1997 and implemented 
> >> on >July 1, and that Geoff had assumed the title of Telstra Internet's 
> >> Technical Manager on or around the same time. After that he continued 
> >> to advocate the same position, e.g., in the context of the IETF 
> >>  >"Pricing for Internet Addresses and Routing Advertisements" (piara) 
> >> BoF.
> >
> >> So while Geoff's world-class expertise in BGP is unquestionable, his 
> >> seemingly consistent preference for market-based vs. 
> >> need/capability-based resource management must be based on something 
> >> else.
> >
> > I never claimed that Geoff Huston, whom I have never met, did not have a 
> > preference for market-based solutions, only that he did not view the 
> > danger of disaggregation as a reason to have needs requirements for 
> > transfers.
> Why are you attempting to change the subject to disaggregation? I thought 
> your proposal was based on claims about the best way to maintain whois 
> accuracy?
> I'm not changing the subject to disaggregation, in fact I mentioned that 
> this was one of the points noted in opposition, please reread the entire 
> thread from this morning.

>Got it -- this was a red herring. Moving on...

A red herring is an attempt to divert. Something you have done rather 
consistently in this thread. My mention of disaggregation came here, in a 
post on 5/18 at 11:23:

The objections I have noted seem to fall in three categories:

1. That's not the way we have historically dealt with addresses.
2. It could lead to disaggregation
3. Hoarders and speculators will appear and will unfairly manipulate price.

I was pointing out in a recap of prior commentary, what the objections to my 
proposal were. How is this in any way a red herring?

> > Unless you are implying that his preference for market-based solutions 
> > has somehow overridden his BGP expertise, my point stands.
> I decline to speculate about Geoff's innermost thoughts on this matter. 
> Geoff has a vast reserve of hard experience dealing with market mechanisms 
> in the BGP world, but even he hasn't advocated pure free-market routing at 
> all places and times. But then my experience discussing matters like these 
> with people all over the world for the last decade or so has left the 
> impression that world-class expertise in BGP is perfectly compatible with 
> radically opposing, mutually incompatible views -- not only concerning the 
> best way to maintain a protocol number resource registry, but even about 
> the proper way to manage global interdomain routing. Opinions on the two 
> subjects seem to be quite independent and unrelated, at least in most 
> people.
> Of course there is undeniably a subset of people (in fact, one that's is 
> quite well represented in this industry) who believe that unrestricted 
> market mechanisms represent the ideal solution for every problem at all 
> times and places. I find it a lot easier to assume that you fall within 
> that group -- esp. since you have more-or-less self-identified yourself as 
> a member.
> I do support voluntary markets as optimal mechanisms for resource 
> allocation. But Geoff was brought into this only to demonstrate that 
> somebody with more BGP expertise than me thought that the threat of 
> disaggregation was not greater than the threat to Whois represented by 
> needs requirements for transfers.

>Sigh. If only you were willing to show as much deference to those with more 
>Internet number registry expertise than you... many of whom have been very 
>patiently attempting to help you understand why >this proposal is a bad 

Some of the posters have made intelligent points which have led to the 
proposal being modified to require RSA and limit needs-free transfers to a 
/12 as a means to gain consensus.
And I'm not really sure how well you have appraised my experience level.

[Note: I added the word "patiently" above to clearly signal that I do not 
count myself among said group]


> >> Besides, wasn't it you who just recently rejected (my) suggestion that 
> >> observations based on the historical experience(s) of other registries 
> >> could provide insight on the merits of your proposal?
> >
> > You suggested that the historical experience of the DNS registry was 
> > applicable, but I still have not seen an apples-to-apples comparison 
> > worthy of providing insights. For the DNS registry to inform us, we 
> > would have to compare an experience of  for-pay DNS registries *with a 
> > needs test* to for-pay DNS registries *without a needs test*.
> Okay, I concede your point.
> And based on the same logic, I suggest that this proposal should be 
> abandoned on the grounds that no one can claim to have any relevant 
> "apples-to-apples" experience, or to have have any defensible 
> "apples-to-apples" basis for assuming that this proposal has any chance of 
> making it easier to maintain whois accuracy going forward.
> My logic says that analogies have to be apt to be informative. Your logic 
> says that nothing new can be proposed.

>As far as I can tell, you have discounted not only analogies, but also 
>logic. Your reasoning appears to be insusceptible to any/all 
>counter-evidence and counter-argument when it comes to the axiomatic 
> >superiority or market-based mechanisms -- which means of course that 
>"reasoning" is not really the right term to use.

It's a ludicrous test to request proof of the extent of damage of unintended 
consequences before a proposal is allowed to continue.  Basically, you are 
somehow postulating that I am stating that zero registrations will happen 
off the books if my proposal advances. A logical fallacy that leads to 
additional logical faults, like believing that a showing that a single 
entity who does not wish to be registrered somehow has some logical effect 
on my proposal. You set up a series of straw man logical arguments unrelated 
to my proposal, and think that the readers can't see through that?
How does the existence of an entity who wishes to scam the registration 
system have any effect on my proposal, can you answer that direct question?

>You have a right to your own faith, but not to your own logic -- much less 
>a right to redefine logic for everyone else.

Its not a redefinition, it's just that logic has to be applied rationally. 
If you make a mistake on your initial logical test, as you did, then 
everything that follows is mistaken.
Unless you can demonstrate why you think your logical questions relate to my 
proposal, they remain separate and independent, and meaningless.

>  And I point again to the unusual aspects of the MS/Nortel deal as 
> evidence that had the needs requirement not very fortunately aligned with 
> the prior facts of the sale, the transaction would likely have occurred 
> and led to Whois inaccuracy. Care to address the fact that of the universe 
> of publicly accessible data on transfers, 100% of the deals required 
> fortuitous needs findings in order to maintain Whois accuracy?  And also 
> please consider whether you think it legal for a legacy holder to transfer 
> addresses without being subject to ARIN's needs requirements, and by 
> transfer I mean pay money for and then route, NOT having ARIN update 
> Whois.  My reading of the bankruptcy docs showed the judge viewed Nortel 
> as having the exclusive right to transfer the addresses.
> Per this article, it's not only Mike Burns who feels that all ARIN can do 
> with these transactions is withhold Whois updates.
> http://www.networkworld.com/news/2011/051111-nortel-ipv4-sale.html

>Per (the majority of people who have responded to your proposal on this 
>list), I am not the only person who thinks that what you advocate would be 
>reckless and counterproductive.

The difference, Tom, is that everyone involved in this discussion reads the 
list and knows that, but not everyone is exposed to the words of the lawyers 
and academics quoted in the article.

>Per (the majority of people who lived through the last 3-4 years), I 
>wouldn't be the only one who believes that there are all sorts of perfectly 
>legal market-making activities that Mike Burns could >undertake to advance 
>his own private agenda, which could if widely adopted rapidly precipitate 
>the end of private sector governance in this domain.

That sentence doesn't make any sense, I suppose it's meaningful if we leave 
off the intitial clause. And again with the personal assault on my 
motivations and the presumption that I don't act out of stewardship. 
Congratulations on your belief. I believe that if we don't act to make Whois 
a title registry that accurately reflects legal transactions, we run the 
risk of private registries filling the void of accurate information, and 
THAT could precipitate the end of community governance in this domain.

>Per (lots of former homeowners, former employees of AIG, Lehman Brothers 
>and many other banks, as well as former employees of every non-banking 
>sector in the US and elsewhere), I am sure that I >won't be the only one 
>who's going to be sorry if you insist on pursuing that agenda, damn the 

Well, you certainly attribute a lot of power to me, since my pursuing my 
agenda will make many sorry. I only wish that were so! ;-)

>The only real question is: will our collective regret be more like the 
>regrets of former employees of Enron et al. who helped to trigger the 
>dot-com collapse -- though not before a (very) few got very rich ->- or 
>more like the regrets of former employees and members of the private banks 
>and independent clearing house associations that disappeared and/or 
>permanently lost their self-governance prerogatives >back in 1913.

>Mike Burns may be the only person in this debate who's willing to refer to 
>himself in the third person, but I am not the only one who worries about 
>such gloomy possibilities...

My point above was that real transactions in the real world occur, 
particularly with legacy space, that run the risk of not being recorded in 
Whois due to the needs requirement.Often in this debate, and again in this 
very message (remember your  "some marginal degradation") the point is made 
that the number of these transactions is minimal, and there are some 
academics who require proof of these transactions, which obviously are 
desired to remain private. Where the number of transactions that we can 
publicly point to is very limited, we have to derive as much information as 
we can from the public sources available. Which is what I have done, and by 
pointing to the article, I am hoping to establish that others have read the 
same public legal papers and come to the same conclusions. And yet again, 
you have failed to acknowledge the facts of the MS/Nortel deal which show 
that absent the fortunate needs finding, the deal would likely have 
happened, Microsoft would route the addresses, and Nortel, or one of it's 
ancient acquisitions, would be the Whois registrant. But I suppose that is 
just a marginal degradation.


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