[arin-ppml] Initial ISP Allocation Policy

[Jon Daniels]

Hi Leslie,

Thank you for your reply.  I have been following the policy proposals
with interest.

> A VPS provider assigns IP addresses to virtual servers that are operated
> by customers.  Therefore, a VPS provider is not an end user as they are
> assigning IP addresses to equipment/infrastructure they don't operate.

Using this interpretation, does this mean ARIN considers a web hosting
provider to be an ISP?  They also assign IP addresses to websites
(infrastructure) that are operated exclusively by customers.

Do the folks at ARIN who are making this interpretation understand
that a VPS is not hardware, but software?

-Jon

On Tue, Jul 23, 2013 at 8:10 AM, Leslie Nobile <leslien at arin.net> wrote:
> Hi Jon-
>
> My apologies for the late reply to your question below.
>
> Just to clarify, ARIN does consider VPS providers to be ISPs.  As defined
> in NRPM 2.8, an end user is an organization receiving assignments of IP
> addresses exclusively for use in its operational networks.  We interpret
> this to mean "for assignment exclusively to equipment/infrastructure it
> operates".
>
> A VPS provider assigns IP addresses to virtual servers that are operated
> by customers.  Therefore, a VPS provider is not an end user as they are
> assigning IP addresses to equipment/infrastructure they don't operate.
>
> Please note that the community is currently discussing 2 policy proposals
> on ppml that will potentially change the definition of ISP and end user
> (pp 2013-5 and prop 190).
>
> Regards,
> Leslie
>
>
> Leslie Nobile
> Director, Registration Services
> American Registry for Internet Numbers
>
>
>
>
> On 7/17/13 6:10 PM, "Jon Daniels" <jdaniels at forked.net> wrote:
>
>>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?
>>>
>>> ISPŠ $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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