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

Chris Engel cengel at conxeo.com
Fri May 20 12:40:40 EDT 2011

> On Thu, May 19, 2011 at 05:49:43PM -0400, Mike Burns wrote:
> > Blake,
> >
> > My proposal includes a limit of /12 of needs-free transfers
> > specifically to prevent hoarding and market cornering. (It's a recent
> > addition.)
> I assumed it was speciifcally to create business for lawyers
> specializing in creating legal entities to hold address space, since
> someone wanting to hoard a /8 would, under your policy, need 16
> different legal entities.
> If we assume there are going to be serious speculators involved if the
> needs requirement is eliminated, we would also reasonably have to
> assume they won't be deterred by a requirement to create a stack of
> entities under their control in practice, but nominally sufficiently
> distinct to prevent their holdings from being aggregated for the
> purposes of the /12 rule.
> In this post, I'm taking no position on the merits of transfers w/o
> needs justification, just pointing out that the /12 limitation is
> trivial to get around and is effectively a no-op.
>      -- Brett


Under that same scenario, what is to stop the same speculator from creating 16 different legal entities that purchase IP-Enabled devices (i.e. pet rocks) from the parent company to show it meets it's "needs" and "utilization" requirements under a "needs" based regulatory requirement for transfers?

It strikes me as a "no-op". If a dishonest actor has sufficient expertise and resources to fool ARIN staff into allowing more allocations then policy would allow, then I would argue it has equal ability to fool ARIN staff into believing it has legitimate need for those addresses when it doesn't.

Tossing aside any philosophical arguments for a moment, from an entirely practical standpoint that's why I don't see a "needs" based requirement for transfers amounting to very much of anything in a scarcity market. In the past when the value of IPv4 address space was relatively low, it wasn't really worthwhile for anyone to throw alot of resources into obtaining more then they had a use for. Therefore effective enforcement didn't require a ton of resources either. If IPv4 space actually starts gaining some real monetary value (as it seems to have) in a scarcity market, unless you start throwing alot more resources at enforcement efforts then the effectiveness of enforcing adherence to policy increasingly declines.

>From my perspective, in a scarcity market.....at best "needs" based justification controls are open enough that it becomes a non-factor one way or another....Anyone with a legitimate need can get approval for a transfer....AS can anyone who has enough resources and basic knowledge to fabricate legitimate need... essentially a rubber stamp. At worst, enforcement efforts get increasingly complex and arbitrary....and you do catch alot of the people attempting to game the system.... BUT you ALSO get alot of false positives where organizations with real legitimate needs get denied simply because they lack the experience and inside knowledge to know how to navigate the increasingly complex and arbitrary rules for demonstrating need..... and it simply becomes an "insiders" game....where it's not what you need but what/who you know that determines approval.

Personally I'd prefer a system where speculators are allowed into a system to one where legitimate organizations are kept out simply because they lack the knowledge/experience to get past the enforcement process. YMMV.

Christopher Engel
(representing only my own views)

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