[arin-ppml] Hoarding and speculation (was: Re: Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification)
jcurran at arin.net
Wed Sep 24 07:54:38 EDT 2014
On Sep 23, 2014, at 10:45 PM, David Huberman <David.Huberman at microsoft.com> wrote:
> What is the virtue of a limit?
> It's not the prevention of speculation and hoarding. Those will always
> happen outside the view of ARIN policy.
> Before anyone answers this, please ensure you're knowledgeable about
> the IPv4 market today. I am.
> There's no speculation that I can find, short of a one-off speculator
> who is a well-known fraudster.
> ARIN's job should simply be to verify the seller is the bona fide registrant,
> and that the seller agrees to the transfer, and that the buyer signs an
> RSA and pays whatever fees are necessary to cover the costs of the
> transaction processing.
You describe an interesting "present state", and presuming it is
well-informed, it is probably extracting and making explicit some
points in your worldview before continuing the discussion.
You indicate -
1) Hoarding and speculation can happen outside of ARIN's view
This is almost certainly the case, as parties always free
to contract for future behavior, including a party ceding
its ability to transfer address rights to any other party.
2) A limit on the size of transfers cannot meaningfully deter
hoarding, due to point #1 above.
3) A limit on the size of transfers cannot meaningfully deter
speculation, due to point #1 above.
4) Hoarding does occur, but there is no meaningful speculation
that you can find.
By "hoarding", I believe that you mean parties obtaining
right to number resources in anticipation of future need
to make use of them, as opposed to "speculation" whereby
one obtains rights in anticipation of financial gain.
If you are correct above, it does raise the question of "why
isn't there abundant & apparent speculation going on today?"
It can't be for lack of interest; investment firms will speculate
on nearly anything that has good potential to beat the market.
I've had investment firms ask about the 'rules and regulations'
that apply to transfers of IP address rights for this very reason.
The various policy merits of allowing hoarding or speculation are
not mine to argue; that is for the community to ponder through the
policy development process. However, you propose that we simplify
ARIN processes and make ARIN policy fit reality; effectively that
ARIN's job should simply be to verify the seller is the bona fide
registrant and that parties agree to the transfer.
If community does as you suggest, both hoarding and speculation
become readily available, and this represents a significant change
from the present state as described by your worldview. A change
which simply formalized the present state that you describe would
not enable speculation, since you do not view that as abundant in
the present system. The difference between the two outcomes comes
down to whether or not the buyer is obtaining the resources in
anticipation of future need or simply financial gain, i.e. is the
buyer of the rights to the addresses a bona fide network operator.
I'll assert that the present system is actually rather unfavorable
to speculation; parties that seek to obtain the rights to address
blocks without the real potential for future use are run a very risk
of ending up in violation of policy and with impaired investments
as a result. More specifically, your postulate [#3] above to the
effect that a limit on the size of transfers cannot meaningfully
deter speculation is likely not valid - the limit does indeed deter
speculation today, as having to qualify eventually against needs-
based limit requires the party to actually operate a network (or
risk total loss of the investment, likely beyond the risk profile
of the vast majority of potential investors.)
Unless you are advocating for a policy shift to enable speculation,
simplification of ARIN policy towards your "present reality" needs
to be more than simply verifying that the seller is the bona fide
registrant and that parties agree to the transfer; in particular,
verification that the recipient is a bona fide network operator
would also be required. That is an aspect presently implied in the
needs-based limit on the size of an address rights transfer, but
that element could be made explicit and retained, if limit itself
is otherwise undesirable in your view.
Interesting discussion - Thank you!
President and CEO
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