[arin-ppml] 2016-3 Revisited

[Owen DeLong]

> On Feb 3, 2017, at 15:03 , Mike Burns <mike at iptrading.com> wrote:
> 
> Hi Owen, replies inline in quotes.
>> 
>> 1. IPv4 value will be zero after the IPv6 transition
> 	Which does nothing to prevent speculative transactions placing bets against this
> 	transition through IPv4 market manipulation.
> 
> "Wrong. It puts the fear of an un-timeable transition foremost in the mind of any potential speculator.”

That depends on how well resourced and how confident the speculator is in their ability to achieve their desired goal, which may not necessarily be directly profiting from the resale of the IPv4 addresses in question.

>> 2. IP address transfers are publicly recorded so there can be no 
>> invisible move to control the market
> 	Except that the public information is rather limited and there’s nothing that guarantees a single
> 	actor is visible as a single Organization.
> 
> "Here is why I roll my eyes. Think about what you are suggesting. Some multi-billion dollar enterprise is going to engage in shady dealings, attempting to hide their true identity behind bogus ORG-IDS or the like.  Signing C-Level notarized attestations. All to corner a market, the cornering of which will surely speed the transition to IPv6 and an IPv4 value trending towards zero. “

I realize that this sounds almost as ridiculous as a major automobile manufacturer falsifying emissions reports, but hey, what do I know.

>> 3. IP address rights are subject to change by stakeholders
> 	Within the limitations of the RSA which is rather rigid, actually.
> 
> "The RSA is mutable, obviously, and there are several other policy-based mechanisms up to and including restoring utilization requirements.”

No, the RSA can be modified for future signatories, but we don’t have the power to strip away existing protections from those that have already signed the agreement.

>> 4. RIPE has had a no-needs policy for quite a while with no evidence 
>> of manipulation
> 	Simply not true. RIPE has a questionable needs policy IMHO, but it is still a needs-based policy.
> 
> "Owen I believe you to be simply wrong on this. RIPE needs-tests inbound inter-regionals only. RIPE does have a 2 year resale hold.”

I stand corrected… The RIPE policy is, in fact, more questionable than I was previously led to believe.

Nonetheless, absence of evidence (which I’m not convinced is entirely true, I simply don’t have any that I can provide without violating NDAs).

>> 5. The IPv4 supply market has been fragmented by 30 years of 
>> distribution
> 	Not sure how this contributes to preventing speculative transactions. Many stocks are speculatively traded every day
> 	which have been on the market for far more than 30 years. Companies more than 30 years old have been subject of hostile
> 	takeovers.
> 
> "To make this clear, there are no suppliers taken individually or together, who are able to sell enough addresses to manipulate the market. This situation is a result of RIR and Pre-RIR distributions to thousands and thousands of discrete organizations. What's more, should any attempt to rig the market take root, rising prices will tend to shake loose more supply, requiring continued (clandestine!) purchases. The total aggregate space transferred to date would not be enough to move the market even if it all went to one buyer, IMO.”

Moving the market is not the only possible objective of such manipulation.

>> I know that you are aware that there is no one-stop-shopping for large IPv4 address blocks, and there are not now nor have ever been enough addresses on the market to come close to levels required for manipulation.
> 
> Manipulation of a market only requires gaining control of a substantial portion of the market, not necessarily the total of all IPv4 addresses. Indeed your statement here would support the idea that the small market is easier to manipulate rather than more difficult.
> 
> "This market is impossible to manipulate in my opinion, given current circumstances and the Sword of Damocles hanging over it in the form of IPv6 transition.”

You are only considering one possible target of manipulation (namely an attempt to maximize the resale price of the addresses hoarded). There are other possible goals.

>> The whole thing is farcical in my mind, and as a broker of more than 350 transfers I think I have as good a window on this market as anybody.   So I just have to point out when we engage in this discussion that we are tilting at windmills and my posts are exaggerated eye-rolling attempts.
> 
> While I appreciate your colorful characterization of those of us with opposing views as much as anyone else, I find your belief that the market is free of manipulation or that there is no need to make efforts to prevent same to be equally worthy of a donkey and substantial eye-rolling.
> 
> 
> "At least I am not the one making rules based on frankly unsubstantiated fears. Where is your evidence?”

Where is your evidence that there is no manipulation, no speculative transactions, and nothing going on underground?

You’ve presented no contrary evidence. You’ve only made unsubstantiated claims that because I cannot produce proof of a black market or other clandestine transactions that you don’t believe they are occurring.

All either of us can work with is our opinion. Again, absence of evidence isn’t evidence of absence, no matter how much you would like to claim that is the case.

I can’t personally prove that front-running orders happens in the stock market, but I’m pretty sure it does.

Owen

> 
> Regards,
> Mike
> 
> 
> Owen
> 
>> 
>> Regards,
>> Mike
>> 
>> 
>> 
>> -----Original Message-----
>> From: David R Huberman [mailto:daveid at panix.com]
>> Sent: Friday, February 03, 2017 11:04 AM
>> To: Mike Burns <mike at iptrading.com>
>> Cc: 'Jason Schiller' <jschiller at google.com>; arin-ppml at arin.net
>> Subject: RE: [arin-ppml] 2016-3 Revisited
>> 
>> 
>> Mike,
>> 
>> For clarity, your last question - the final paragraph - what smooth section is that?  Existing NRPM 8.5, or 2016-3 without the anti-abuse clause?
>> 
>> David
>> 
>> 
>> On Fri, 3 Feb 2017, Mike Burns wrote:
>> 
>>> Hi David,
>>> 
>>> 
>>> 
>>> I appreciate you trying to make me understand.
>>> 
>>> So are you assuming in your example that you seek to purchase space that you do not need for your business purposes.
>>> 
>>> My argument is that organizations do not purchase space for which they don’t feel there is a valid business purpose.  Now it’s true that an organization’s perception of need will vary from the one which is being rigorously defined here, but there is an obvious brake on the purchase of items for which there is not a business purpose.
>>> 
>>> 
>>> 
>>> And for those whom we are imagining who are determined to somehow go around policy to acquire un-necessary space, there are already plenty of workarounds, the simplest of which is to acquire RIPE space.
>>> 
>>> 
>>> 
>>> Am I missing something obvious that requires this additional complexity to what was a nice smooth section of the NRPM?
>>> 
>>> 
>>> 
>>> Regards,
>>> 
>>> Mike
>>> 
>>> 
>>> 
>>> 
>>> 
>>> From: David Huberman [mailto:daveid at panix.com]
>>> Sent: Friday, February 03, 2017 10:43 AM
>>> To: Mike Burns <mike at iptrading.com>
>>> Cc: Jason Schiller <jschiller at google.com>; arin-ppml at arin.net
>>> Subject: Re: [arin-ppml] 2016-3 Revisited
>>> 
>>> 
>>> 
>>> Mike,
>>> 
>>> 
>>> 
>>> I buy a /13. I abuse the spirit of 2016-3, meant for smaller transfers as our first attempt at no needs testing, by reiterating /16 transfers one after the other.
>>> 
>>> 
>>> 
>>> Market pricing doesn't stop this, and the ARIN community who participates in public policy matters has made it clear that an incremental approach towards needs testing is a good thing.
>>> 
>>> 
>>> 
>>> David
>>> 
>>> Sent from my iPhone
>>> 
>>> 
>>> On Feb 3, 2017, at 10:34 AM, Mike Burns <mike at iptrading.com <mailto:mike at iptrading.com> > wrote:
>>> 
>>> 
>>> 
>>> If that approach still doesn't work can you suggest some other mechanism to prevent abuse that does not prevent an organization who needs IP space from using this policy?
>>> 
>>> 
>>> 
>>> 
>>> 
>>> Hi Jason,
>>> 
>>> 
>>> 
>>> Why are we ignoring the mechanism that prevents organizations from buying un-needed anything? To wit, they have to pay money for these addresses. You guys are spinning up unlikely scenarios and ignoring the 800lb. elephant in the room… the cost of these addresses is the mechanism you seek.
>>> 
>>> 
>>> 
>>> Regards,
>>> 
>>> Mike
>>> 
>>> 
>>> 
>>> 
>> 
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