[arin-ppml] ARIN Draft Policy 2014-2 Improving 8.4 Anti-Flip Language

William Herrin bill at herrin.us
Mon Feb 24 12:50:50 EST 2014

On Fri, Feb 21, 2014 at 11:53 AM, Bill Darte <billdarte at gmail.com> wrote:
> Three alternatives were primarily discussed and I wish to elicit feedback
> from the community relative to each.
> 1. Use the existing last sentence as is and ask ARIN staff to be
> particularly watchful for seeming abuse and to bring such back to the
> community through regular Policy Experience Reports.  There was discussion
> about this option suggesting that by the time abuse was recognized and
> reported, and given limited existing free pool stocks and the extended
> policy development cycle....this option may be moot.
> 2. Remove the clause 'and its subsidiaries' or modify it in such a way as to
> mitigate the risk of a laundering of addresses through fraudulent transfers,
> but this may still potentially limit the utility to organizations who may
> have complex organizational structures in use internationally.
> 3. Take an alternative tack and simply restrict transfers on a per-block
> rather than a per-organization basis. e.g. 'No block acquired within the
> past 24 months would be eligible for transfer.' (The time frame is of course
> an arbitrary number at this point.)


My preference is for #2: remove the clause. Moreover, I question
whether this matter requires policy action at all.

As was recently and eloquently pointed out to us, organizations can
and do receive the beneficial use of blocks of IP addresses without
effecting a transfer at the registry. In the case of a subsidiary
which will remain a subsidiary for a policy-relevant period of time,
nothing is lost by processing contact via the parent organization.
Why, then, should ARIN create a loophole in the regulations and risk
its abuse?

Loopholes = bad. Allow open transfers or don't, but please don't
create loopholes for folks to abuse.

Bill Herrin

William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
Falls Church, VA 22042-3004

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