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

William Herrin bill at herrin.us
Mon May 5 18:12:43 EDT 2014

On Mon, May 5, 2014 at 5:48 PM, Scott Leibrand <scottleibrand at gmail.com> wrote:
> Bill Herrin makes a good point: many of the ideas we've been discussing in
> the context of 2014-2 are really a more general relaxation of transfer
> policies, and probably should be considered separately.  However, I think
> that statement (#2 above) represents something pretty close to the consensus
> I heard in Chicago.  Given that it also addresses the 2014-2 problem
> statement, I think that might be the direction we need to be going here.
> Thoughts?

Hi Scott,

That defeats the anti-flipping provisions entirely. It costs all of a
couple hundred dollars ($2000 if you jump through -all- the hoops) to
create a subsidiary. It's trivial. You then sell the subsidiary
replete with addresses. The buyer doesn't even have to register
separately with the RIR. $10 domain name for the POC and google voice
account included.

Worse, as implemented in this proposal it creates an unfair bias
favoring out-migration of addresses since transfers to subsidiaries
within the region are covered by a different policy. This policy
proposal is biased against the domestic folks it is ARIN's core
mission to serve!

My view now is the same as it was in February:


"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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