[arin-ppml] FYI -- RIPE-605 Services to Legacy Internet Resource Holders

Steve Noble snoble at sonn.com
Mon Feb 17 16:08:04 EST 2014

As a holder of both legacy and non-legacy ARIN objects, I have been 
subject to ARIN's registry update blocks on _non-legacy_ objects that I 
rightfully control and use.  I spent years (6 I believe) fighting with 
ARIN to update the information on one of my ASNs while ARIN continued to 
bill me for a 'service' which they did not provide.  ARIN's 
unwillingness to update the database to have correct contact information 
is not only an undesirable effect of their policies, but also an 
indication of ARIN's lack of concern about having correct information in 
the database.

  As a consumer, I see no value to the service that ARIN provides. I pay 
ARIN's fees only to keep ARIN from giving the AS that I use to someone 
else and causing an administrative issue to become an operational issue.

> Lindsey, Marc <mailto:mlindsey at lb3law.com>
> February 17, 2014 at 11:53 AM
> I advise several large legacy block holders.  Some of them signed the 
> LRSA, but many have not.  For them, the burdens imposed by the LRSA 
> outweigh the benefits.   Some on the PPML have suggested that 
> off-contract legacy holders don't sign up with ARIN because they want 
> to be free-riders.  But the fees (and the avoidance of the fees) are 
> not a factor in their LRSA decision.
> Based on my experience working with legacy block holders, I believe 
> adopting a policy substantially similar to RIPE 605 (ARIN prop 203) 
> would go a long way in harmonizing the interests of the ARIN community 
> with the community of legacy holders that do not have formal 
> relationships with ARIN.
> ARIN's absolute control over additional allocations of "free" IPv4 
> numbers in its region has served as the primary policy enforcement 
> mechanism.  This carrot really only works on recipients that need more 
> IPv4 numbers, and then only as long as ARIN has free numbers to give 
> out.  It doesn't directly influence the behavior of many legacy block 
> holders when they convey their spare numbers.   Legacy holders are a 
> major source of future IPv4 number distributions, and their relevance 
> to the broader ARIN community will become more prominent as ARIN's 
> IPv4 free pool reaches depletion.
> In the secondary market context, ARIN now relies on its ability to 
> withhold registry database updates as the primary means to extend 
> enforcement of its current policies into private transactions between 
> parties conveying beneficial use of IPv4 numbers.  This, however, is a 
> weak enforcement tool. Two parties can convey beneficial use of IPv4 
> numbers in lawful commercial transactions without updating ARIN's 
> registry database.  But IPv4 number conveyances not recorded in the 
> registry system produces very undesirable results -- the "reality" in 
> the registry database will not reflect operational reality, as David 
> Conrad and others have pointed out in several posts.
> Buyers and sellers would prefer to document their conveyances in a 
> reliable and accurate public registry, but not if the contingencies 
> and conditions materially and adversely affect their commercial 
> arrangement.  RIPE 605/ ARIN prop 203 recognizes this reality.  With a 
> little tweaking, adopting it would go a long way in minimizing the 
> disincentives now facing legacy holders (and entities that want to 
> acquire their numbers) when contemplating whether updating the 
> registry database is worth the risk of subjecting their transactions 
> to ARIN's approval process.
> *Marc Lindsey*
> Levine, Blaszak, Block & Boothby, LLP
> 2001 L Street, NW Suite 900
> Washington, DC 20036
> /Office:/ (202) 857-2564
> /Mobile:/ (202) 491-3230
> /Email:/ mlindsey at lb3law.com <mailto:mlindsey at lb3law.com>
> Website: www.lb3law.com <http://www.lb3law.com>
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