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

Mike Burns mike at nationwideinc.com
Fri May 20 15:56:13 EDT 2011

Hello to the list,

Per what Tom wrote at the bottom, I am all for considering the consequences 
of my proposal, intended or otherwise.

So I believe the consequences we have considered, and please add to this 
list if you want, are:

1. Market distortions will happen due to the selfish actions of speculators, 
including market cornering attempts.
2. Disaggregation will increase.
3. It is too radical a change, and change should appropriately come 
incrementally, like extending the length of the needs window.
4. It will make it easier for bad players like spammers to get addresses.
5. It will run the risk of actually making Whois less accurate.
6. Addresses will be used less efficiently if we only rely on price to drive 
their productive use.

I figure we have addressed these issues enough, and that we are rehashing 
discussions to no additional benefit.

And I have had the opportunity to address the intentions of the policy 
proposal, which are:

1. Provides an incentive for more transactions to be registered by ARIN
2. Provides an incentive for legacy space to be brought under RSA
3. Provides for explicit protections against review audits for RSA holders 
after one year, bringing RSA rights more in accord with LRSA rights.
4. Reduces transaction costs for transferers
5. Reduces ARIN costs for needs analyses
6. Aligns ARIN policy with most possible interpretations of the legal rights 
of legacy holders
7. Imposes a yearly limit on needs-free transactions intended to prevent 

And likewise we have fairly addressed these issues.

Without considering (any more) the merits of those prior discussions, I 
would like to invite the consideration of any other potential benefits or 
consequences which we have not discussed.
I am cognizant that this is proposal is a significant departure, and that 
the discussion of similar policy in APNIC consumed several years.
I think we have covered pretty much all the bases in our relatively short 
but active discussion period, but I agree with Tom that we really should 
stretch our minds to consider all the potential pitfalls.
So did we miss anything, or is there anything left to be said on the topics 
arrayed above? Any large loopholes or gotchas? Risks or threats we haven't 
Maybe the increased/decreased exposure of ARIN to lawsuits?

(I will admit to enjoying reading my own words. But as they are growing 
tiresome to me, they must be coma-inducing to you by now.)

Of course I don't mean to cutoff any discussions about any topic, if you 
think there is more to add.


----- Original Message ----- 
From: "Tom Vest" <tvest at eyeconomics.com>
To: "Chris Engel" <cengel at conxeo.com>
Cc: "Mike Burns" <mike at nationwideinc.com>; <arin-ppml at arin.net>
Sent: Friday, May 20, 2011 3:09 PM
Subject: Re: [arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

On May 20, 2011, at 1:24 PM, Chris Engel wrote:

> Tom,
> Excising a particular section of this thread for the sake of brevity...
>> Fair enough, you prefer to argue logic rather than facts:
>> 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.
>> 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).
>> 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.
> I don't think the above is a fair tactic for debate. You are asking Mike 
> to prove a logical fallacy. Furthermore, when you start using words like 
> "never" and "always" when discussing human behavior as benchmarks for 
> judging the legitimacy of a system...your standards themselves appear 
> absurd. If we applied the same standards for judging the appropriateness 
> of a "needs" based policy, it would assuredly fail as well. Systems 
> designed to regulate human behavior cannot achieve a uniformity of results 
> approaching mathematical perfection, nor need they do so to be effective 
> (IMO).
> If you want to argue that it's likely a substantial number of individuals 
> would have logical reasons for not wanting to maintain accurate 
> registration under the policy Mike proposes...that's (IMO) a reasonable 
> standard to base an argument on. Not sure whether I would agree with that 
> proposition or not...but the standard is reasonable. Asking Mike to 
> provide a standard of proof that couldn't allow for even a single 
> exception isn't (IMO).
> Christopher Engel
> (Representing only my own views)

Hi Chris,

Thanks for the reactions. Of course you are right on this count. My 
apologies to Mike for demanding what is, technically, logically impossible 
to deliver.

My intent was not to be merely hyperbolic, but rather to *strongly* suggest 
that we all engage our imaginations fully when considering the range of 
strategic responses that might seem to be "rational" from the perspective of 
any clever entrepreneur who may or may not have any long-term interest in 
what happens to the Internet or to others who count the Internet for their 
livelihood or anything else, once s/he is done. Granted, this year we're all 
operating in an environment that has been significantly shaped by the 
unintended consequences of last year's strategic adjustments to the previous 
year's entrepreneurial cleverness, and so on... I mean, who could have 
anticipated that DWDM might trigger changes in SFP policies that helped to 
ignite our first crash, or that widespread diffusion of P2P might prompt 
another shift in commercial strategy that could in turn precipitate a run on 
the ASN16 reserves?

Suffice it to say that there are always plenty of smart people out there 
working out every conceivable new angle that might be exposed by the next 
change in policy and/or technology and/or market structure -- and in 
general, at most times, we all benefit tremendously from that fact. But that 
only remains true as long we do not, through omission or commission, open up 
any loopholes that are big enough to allow to whole industry to fall 
through, into who-knows-what. These days it's not really possible to doubt 
that such things can and in fact do happen from time to time.

I submit that the removal of "capability" testing would not only represent 
an irreversible change, but also has the potential to create a number of 
potentially fatal loopholes. And so in this particular case, I recommend 
that we proceed only if/after we can first achieve a very high level of 
confidence that no serious risks or threats are immediately created thereby.


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