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

Kevin Kargel kkargel at polartel.com
Fri May 20 13:06:43 EDT 2011


> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of Chris Engel
> Sent: Friday, May 20, 2011 11:41 AM
> To: 'Brett Frankenberger'; Mike Burns
> Cc: arin-ppml at arin.net
> Subject: Re: [arin-ppml] IPv4 Transfer Policy Change to Keep Whois
> Accurate
> > 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
> >
> 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.

This is a knee-jerk reaction, but isn't participants having or gaining the knowledge/experience to participate in the process desirable?

> Christopher Engel
> (representing only my own views)

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