[arin-ppml] Initial ISP Allocation Policy

Jon Daniels jdaniels at forked.net
Wed Jul 17 18:10:13 EDT 2013

Is a VPS company an ISP or an end user?

ARIN told me in a ticket regarding an initial IPv4 end-user request
(this is yesterday) that the virtual server (VPS) company i work for,
is NOT an end-user, but is an ISP.  Each virtual servers uses less
than a /29, and we do not do SWIP, reallocate, or reassign any IP
space.  The company only provides virtual servers.

On Wed, Jul 17, 2013 at 2:18 PM, Owen DeLong <owen at delong.com> wrote:
> On Jul 17, 2013, at 4:34 PM, William Herrin <bill at herrin.us> wrote:
>> On Wed, Jul 17, 2013 at 4:02 PM, Justin Krejci <JKrejci at usinternet.com> wrote:
>>> Here is my newbie and possibly naive response.
>>> Without additional details on individual cases in the list, I would expect all of those cases to be "end-users" as none of them are in the business of reallocating address blocks. Right or wrong I've always been under the impression this to be the general rule of thumb: if allowed to reallocate then you're an ISP, else end-user; maybe to back up even further the primary purpose of the listed organizations are not to provide Internet connectivity services nor is it their primary goal or likely even a secondary goal.
>>> Akamai, provide effective access to 3rd party content
>>> Google, provide advertising, searching, and various web related services
>>> U of Maryland, provide education
>>> Starbucks, provide beverages and calories in solid form
>>> Hilton/Marriott, provide hospitality
>>> Linode, provide virtual server hosting
>>> Godaddy, provide DNS/web hosting
>>> In any case, NRPM 2.6 says, "An end-user is an organization receiving
>>> assignments of IP addresses exclusively for use in its operational
>>> networks." I think all of these example cases seem to fit this wording
>>> as they are operating their identified systems within their operational
>>> networks.
>> Hi Justin,
>> What about Verizon Wireless? They're primarily a cellular phone
>> company, and the overwhelming majority of the phones on which IP
>> addresses are used are still on the rent-to-own plan where you have to
>> complete the 2 year contract before you actually own the phone. Untill
>> then you're just leasing the use of their equipment.
> It's my understanding that it is inappropriate to name particular companies in this case, but the below applies equally well to $CELLCO, so I'll speak to that.
> That's not true. If you were leasing their equipment, then you could terminate the contract and give the equipment back to them. Instead, you have to reimburse them for the subsidy (and possibly more in most cases). You bought the phone at a reduced price. You agreed to a service contract in exchange for that reduced price. If you terminate the contract early, you are obliged to pay back said discount.  That is to the same as leasing equipment they own.
>> ISP or end-user?
> ISP… $CELLCO generally assigns a block of addresses to the phone (at least my $CELLCO assigns a /64 to my phone) and should be registering those assignments. Further, they are also providing a service which is intended to provide internet access to customer-owned hardware (your lease argument doesn't actually hold water as stated above). Even if the hardware is leased, it still counts as hardware under the customer's control.
>> What about Comcast? They're in the business of providing cable
>> television service. They'll also provide you with Internet access on
>> the same coax cable with the modem they rent you.
>> ISP or end-user?
> The service is intended to be used to connect customer-owned equipment to the internet. As such, they are clearly in the LIR/ISP realm.
> Owen
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