[arin-ppml] Beneficial Owners

Devon Blake devonrb at gmail.com
Tue Jul 17 17:55:42 EDT 2018


RFG,
Having neither your sensitivity or expertise,  I hesitate to dip my feet in
these Tsunami waters. Be that as it may, I feel your pain, and willingly
join you in asking if their is some redress available through policy or
regulations, which can balance these real or perceived inequities. Over to
the ARIN Administration.
dB

On Tue, Jul 17, 2018 at 10:53 AM <arin-ppml-request at arin.net> wrote:

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> Today's Topics:
>
>    1. Revised - Draft Policy ARIN-2018-4: Clarification on IPv6
>       Sub-Assignments (ARIN)
>    2. Re: Beneficial Owners (Ronald F. Guilmette)
>    3. Re: Beneficial Owners (Ronald F. Guilmette)
>    4. Re: Revised - Draft Policy ARIN-2018-4: Clarification on IPv6
>       Sub-Assignments (Chris Woodfield)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Mon, 16 Jul 2018 14:45:28 -0400
> From: ARIN <info at arin.net>
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Revised - Draft Policy ARIN-2018-4: Clarification
>         on IPv6 Sub-Assignments
> Message-ID: <6f4dd1bf-2234-19ec-6e06-f6ba93ab614c at arin.net>
> Content-Type: text/plain; charset=utf-8; format=flowed
>
> The following has been revised:
>
> * Draft Policy ARIN-2018-4: Clarification on IPv6 Sub-Assignments
>
> Revised text is below and can be found at:
> https://www.arin.net/policy/proposals/2018_4.html
>
> You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion in order to assess the conformance of this draft
> policy with ARIN's Principles of Internet number resource policy as
> stated in the Policy Development Process (PDP). Specifically, these
> principles are:
>
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
>
> The PDP can be found at:
> https://www.arin.net/policy/pdp.html
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
>
> Regards,
>
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> Draft Policy ARIN-2018-4: Clarification on IPv6 Sub-Assignments
>
> Problem Statement:
>
> When the policy was drafted, the concept of assignments/sub-assignments
> did not consider the use of IP addresses in hotspots, or the use of IP
> addresses by guests or employees in Bring Your Own Device (BYOD) and
> many other similar cases.
>
> Additionally, the IETF has recently approved the use of a unique /64
> prefix per interface/host (RFC8273) instead of a unique address. This,
> for example, allows users to connect to a hotspot, receive a /64 such
> that they are "isolated" from other users (for reasons of security,
> regulatory requirements, etc.) and they can also use multiple virtual
> machines on their devices with a unique address for each one (within the
> same /64).
>
> Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such
> assignments, stating that "Assignments... are not to be sub-assigned to
> other parties".
>
> This proposal clarifies this situation in this regard and better define
> the concept, particularly considering new uses of IPv6 (RFC8273), by
> means of a new paragraph.
>
> Note that the proposal text also incorporates changes made under an
> Editorial Change currently awaiting Board of Trustees review, available
> here: https://www.arin.net/policy/proposals/2017_11.html
>
> Policy Statement:
>
> Actual Text, Section 2.5:
>
> ?    Assign - To assign means to delegate address space to an ISP or
> end-user, for specific use within the Internet infrastructure they
> operate. Assignments must only be made for specific purposes documented
> by specific organizations and are not to be sub-assigned to other parties.
>
> New Text:
>
> ?   Assignment - Address space delegated to an organization directly by
> ARIN for the exclusive use of the recipient organization. A temporary
> assignment of address space provided to third parties shall not be
> considered an assignment.
>
> Comments
>
> Timetable for implementation:
>
> Immediate
>
> Anything else:
>
> Situation in other regions:
>
> This situation, has already been corrected in RIPE, and the policy was
> updated in a similar way, even if right now there is a small discrepancy
> between the policy text that reached consensus and the RIPE NCC Impact
> Analysis. A new policy proposal has been submitted to amend that, and
> the text is the same as presented by this proposal at ARIN. Same text
> has also been submitted to AfriNIC, LACNIC and APNIC.
>
>
> ------------------------------
>
> Message: 2
> Date: Mon, 16 Jul 2018 22:50:42 -0700
> From: "Ronald F. Guilmette" <rfg at tristatelogic.com>
> To: "'ARIN-PPML List'" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Beneficial Owners
> Message-ID: <81880.1531806642 at segfault.tristatelogic.com>
>
>
> In message <023101d41d0a$3374d440$9a5e7cc0$@iptrading.com>,
> "Mike Burns" <mike at iptrading.com> wrote:
>
> >Whereas I am sure you will get firm agreement from everybody in this
> >community regarding the abuse of address space, your language leads to
> >conflating the concept of ARIN-"awarded" space and purchased space that
> can
> >be registered anywhere in North America, Europe, the Middle East, or
> Asia.
>
> I hope not, by which I mean that I hope that I haven't either conflated
> the two -or- that I have seemed to be all all against the notion of IP
> address block transfers, e.g. via private brokerage arrangement, because
> I am very much in favor of a free and open market for IPv4 space for
> one simple reason:  My own personal efforts have for many years
> concentrated
> on the problem of so-called "snowshoe" spamming, where the spammers use
> lots of different domain names and lost of different IP addresses to
> evade filters.
>
> This approach to spamming is nowadays employed by 100% of all serious
> professional spammers, and their are two fuels that have driven the
> explosion of snowshoe spamming over the past several years, the first
> being cheap domain names... about which nothing can really be done,
> I think... and the second is cheap IP addresses.  It is my belief
> that to the extent that IP addresses go the highest bidder, they will,
> in general, -not- fall into the hands of snowshoe spammers, whose business
> model only works when there are tons and tons of IPv4 addresses lying
> around that can be had... and burned through... quite cheaply.
>
> >What difference does it make if an Iranian or Pakistani citizen created a
> >Delaware corp and purchased ARIN space and kept it registered in ARIN,
> >versus transferring it to a RIPE or APNIC account in Iran or Pakistan?
> >
> >The addresses can be used nefariously regardless of registry.  ARIN is not
> >issuing space out of any free pool, so the sizes (/19, /17, whatever) are
> >not really relevant...
>
> You're right, of course.  If I am abused from RIPE space or APNIC space or
> AFRINIC space of LACNIC space then the abuse I suffer is neither better
> nor worse that if I was abused instead from ARIN space.  So I don't
> really have a good response.  Call it a kind of IP xenophobia on my part.
> I've just come to have higher expectations with respect to ARIN resources
> than those issued by other regions.  And indeed, those higher expectations
> -are- fulilled in most instances.  I think John and his crew do a rather
> better job of running a tight ship than other RIRs do, and as a result,
> over the years there has been rather less funny business relating to ARIN
> resources.  And in what may be a perverted sort of way, that's what makes
> the situtaions I've alluded to stick out... like the proverbial sore
> thumbs...
> all the more.  Because they are cases of funny business taking place in
> relation to ARIN resources, and when I pull back the curtains I see folks
> from other regions behind it all.
>
> I have an emotional response in such cases, and arguably that's just
> stupid,
> and I really shouldn't.  But nontheless, sometimes I really do think... in
> the heat of battle... that I'd like to build a wall and get RIPE to pay for
> it. :-)  I freely admit that this is not a terribly enlightened viewpoint
> but nontheless I do not apologize for it.
>
> >And what incentive is there for the creation of an American corporation
> and
> >the receipt of ARIN space, versus purchasing ARIN/RIPE/APNIC space and
> >registering it wherever you wish?
>
> Damn good question  I don't know.
>
> I'll stop dancing around in generalities now and talk specifics and maybe
> you can tell me why these folks came to ARIN as opposed to some other RIR.
>
> This mail is already long enough, so I'll present the relevant specifics in
> a separate list post to follow this one.
>
>
> Regards,
> rfg
>
>
> ------------------------------
>
> Message: 3
> Date: Tue, 17 Jul 2018 01:36:38 -0700
> From: "Ronald F. Guilmette" <rfg at tristatelogic.com>
> To: "'ARIN-PPML List'" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Beneficial Owners
> Message-ID: <82441.1531816598 at segfault.tristatelogic.com>
>
>
> Quite reasonably, Mike Burns challenged me as to why I might be
> more irritated to see network abuse, of one kind or another,
> arising out of ARIN-issued resources, relative to the same sorts
> of abuse arising out of resources issued by other RIRs.
>
> As a result, I've been forced to agree that in the context of
> "bad stuff ion the Internet" the specific region it arises from
> is not really all that relevant.  Bad stuff is bad stuff no matter
> where it comes from.
>
> Noneless, I'd like to take a few moments and present two case
> studies that may perhaps illuminate the sources of some of my
> recent annoyances, and then ask for opinions as to what, if anything
> ARIN might be able to do better that might have any bearing on these
> types of situations, in general. ("Fixing" or "actioning" individual
> problem spots is Good, but I, for one, am always looking for generalized
> types of fixes that might alleviate every member of an entire class
> of problems, for the future.)
>
> +_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_+_
>
> Case #1)
> --------
>
> AS16628
> NET-104-171-144-0-1     104.171.144.0/20
> NET-104-237-224-0-1     104.237.224.0/19
> NET-104-237-241-0-1     104.237.241.0/24 -- NOTE: sub-block of
> 104.237.224.0/19
> NET-107-181-112-0-1 <http://104.237.224.0/19NET-107-181-112-0-1>
> 107.181.112.0/20
>
> This one came to my attention just because whoever runs it was giving aid
> and solice, briefly, to a different company named Bicanal, in the form of
> a /24 sub-block of their space that they allowed Mr. Bitcanal to route to
> himself, briefly.
>
> (As some here may be aware, Bitcanal and its owner are not exactly
> favorites
> of mine, and the company and its owner have recently suffered a notable
> loss of quite a lot of their former connectivity, which, in my opinion, is
> all to the good.)
>
> Anyway, it appears to be the case that the actual name of the company in
> this case is really "Dedicated Fiber Communications, LLC", but this full
> corporate name only appears in one out of four of the relevant ARIN IPv4
> WHOIS records, as listed above.   (And that is another small thing that I
> could, and perhaps should beef about.  Why does life have to be so hard
> for us investigators?  Why can't we at least have the WHOIS records for
> all direct ARIN allocations containing the real and full legal name of the
> registrant??  Oh well.  We'll save that small gripe for another day.)
>
> It's possible that there exist many different LLC with this exact same name
> in many different jurisdictions, including in arbitrary overseas countries.
> In other words, as we speak there could be a "Dedicated Fiber
> Communications,
> LLC" which has formal, legal existance in Belize, and another one with
> this exact same name also in U.A.E., another one in the Seychelles Islands,
> the Isle of Man, Scotland, Panama, and so forth, almost ad infinitum.
> And it is even possible that none of these would have anything at all to
> do with any of the others.  So the first step in trying to establish the
> real "who" of any corprate entity is to start by establishing the "where"
> of the entity.
>
> In this specific case, the relevant ARIN WHOIS records give us some clues
> as to where this specific company... the one with the IPv4 blocks... is
> actually located.  But even those clues from the ARIN WHOIS records are
> conflicting.  One of the four lited above says that this company is in
> Scotland, and the rest seem to say it is in Delaware (USA).
>
> In fact, there -does- exist a Delaware LLC with this exact name.  It was
> incorporated in Delaware on 2014-01-14.  In contrast, the web site of the
> UK's "Companies House" corporate registry -does not- indicate that any
> such company is, or has been properly and formally registered within the
> UK.  (And for those of you not well versed in political geography, that
> includes Scotland... for the time being at least.)
>
> Anyway, I wanted to ask the proprietor(s) of this place why they were
> being so kind as to help out Bitcanal in its time of need, so I wrote to
> the contact email address as listed in the relevant ARIN WHOIS records.
> (See above,) That address was/is <noc at dedfiber.com>.
>
> A short while later I got a reply -not- from any @dedfiber.com address,
> but rather from this guy:
>
>     Ali Hajyani <ali at hajyani.info>
>
> RIPE WHOIS records (e,g. AH27894-MNT) as well as other information I found
> online indicates that this guy is actually an Iranian national, most likely
> living and working in Iran as we speak.
>
> Anyway, this fellow seems to be the real registrant behind the set of IPv4
> CIDRs listed above, which includes a /19, and two /20s.  It appears
> most probable that in eary 2014, at the height of the U.S/Iran sanctions,
> this guy got himself a Delaware LLC..,. which he either created or
> bought...
> and within 1 day thereof, he applied for and was issued an ARIN /19 and
> two ARIN /20 blocks.
>
> I have to assume that this all took place at a time when ARIN was still
> flush with available IPv4 space.
>
> I still don't much like it.  I mean we in the United States, and also our
> various allies within North America, the Caribbean, and elswhere, have
> all been waging an ongoing simmering low-level international conflict
> with Iran for lo these past many years... over both their nuclear ambitions
> -and- their support of groups such as Hezbollah.  So on the one hand we've
> been working to make life difficult for them, but then on the other hand
> we appear to have been selling them nice juicy chunks of IPv4 real
> estate.  And we have have been doing so during a time of IPv4 "shortage",
> which makes it all the more inexplicable, to my way of thinking.
>
> Of course, I may just be totally misreading what really took place here.
> Maybe there was an existing company named "Dedicated Fiber Communications,
> LLC" -somewhere- in the world and maybe it got bough by this Iranian
> guy well after it received its IPv4 blocks from ARIN.  But even if that's
> the case, I still have a bit of trouble understanding why and how a
> Delaware company could have been formed fresh on 2014-01-14, like Venus
> arising from the Sea, and then, within one day, on 2014-01-15, ARIN
> felt that this company... which the ink wasn't even dry on yet... should
> get three IPv4 blocks totally the equivalent of a /18.
>
> I confess that my memory isn't that good and I can't really remember
> what conditions were like way back in mid January of 2014.  I can only
> surmize that those were still the golden salad days when ARIN was still
> giving out /20s in every box of CracerJack, and to pretty much any legal
> entity with a total corporate history in excess of a full 24 hours.
>
> Regardless of that, I sill claim the right to be less than entirely
> pleased to know that at that time, ARIN gave the equivalent of an entire
> /18 to some public or private actor who was apparently employing a
> perfectly legal Delaware front company, where said actor was and is
> a resident of an international pariah (Iran) that even the likes of
> China and Russia have never been all that terrifically fond of.
>
> Please note also that Mr. Hajyani also appears to be the proprietor of
> a separate and older company, "Pandilo, LLC" (AS60274, ORG-PA905-RIPE)
> which itself appears to be an Iranian company that once upon a time,
> circa 2010, made a abortive half-hearted attempt to incorporate also
> in the State of Florida (USA).
>
> Perhaps as direct or indirect results of my reports, either public or
> private, regarding the apparent association between Pandilo, LLC and
> Dedicated Fiber Communications, LLC, I see now that bgp.he.net is
> reporting
> that as of July 5, 2018, AS60274 is not routing, and has not been routing
> any IP space whatsoever, even though it was doing so prior to that very
> recent date.
>
> In any case, I do somewhat wonder why Mr. Hajyani is operating these
> two different companies, simultaneously, on the Internet, when it
> seems that just having one would do just as well, and would probably
> be less complicated for him.
>
> But that is not for me to judge.
>
> What does seem clear is that as long as Mr. Hajyani -only- had a
> company (Pandilo, LLC) which was -only- incorporated in Iran, he
> might perhaps have faced more questions when and if he attempted to
> obtain ARIN IPv4 address space, i.e. more than he would if he owned,
> say, a Delaware LLC... which he did, it appears, starting in January,
> 2014.
>
>
> Case #2)
> --------
>
> Secure Internet LLC / Uzair Gadit
>
> NET-104-243-240-0-2           104.243.240.0/24
> NET-104-243-241-0-1           104.243.241.0/24
> NET-104-243-254-0-1           104.243.254.0/24
> NET-104-243-255-0-1           104.243.255.0/24
> NET-104-250-160-0-1           104.250.160.0/19
> NET-104-250-160-0-2           104.250.160.0/24
> NET-104-37-0-0-1           104.37.0.0/21
> NET-107-191-38-240-1           107.191.38.240/29
> NET-108-177-165-0-1           108.177.165.0/25
> NET-142-91-77-128-1           142.91.77.128/25
> NET-162-246-184-0-1           162.246.184.0/22
> NET-172-111-128-0-1           172.111.128.0/17
> NET-172-94-0-0-1           172.94.0.0/17
> NET-173-199-120-248-1           173.199.120.248/29
> NET-192-253-240-0-1           192.253.240.0/20
> NET-192-253-244-0-1           192.253.244.0/24
> NET-206-123-128-0-1           206.123.128.0/19
> NET-45-74-0-0-1           45.74.0.0/18
> NET6-2602-FF84-1           2602:FF84::/36
>
> This company, and specifically the 172.94.0.0/17 block assigned to it,
> came to my attention as a result of an investigation of a sizable group
> of unambiguous snowshoe spamming domains.  A comprehensive scan of the
> reverse DNS associated with each and every IPv4 address within this block
> exhibited a clear and unmistakable pattern characteristic of a large
> scale professional snowshoe spamming operation, at least within a sizable
> subset of this block's constituent /24 sub-blocks, as the relevant
> reverse DNS (PTR) records that existed as of July 12th of this year
> clearly demonstrate:
>
>      https://pastebin.com/raw/kZJyJ5x5
>
> (Note that my reports of the issues within this block to a variety of
> anti-spam organizations apparently resulted in the rapid discontinuation
> of most or all of the relevant snowshoe rDNS shortly thereafter.
> Unfortunately for the registrant of, and for the recent users of
> 172.94.0.0/17, historical records of the applicable rDNS/PTR records
>  as they existed on July 12th, are quite certainly still available for
> public perusal within various passive DNS data bases, and I am confident
> that these will verify and confirm my listing, created on the 12th,
> as presented at the URL above.)
>
> A company by the name of "Secure Internet, LLC" currently is registered
> within the (US) State of Delaware.  It is not known, by me at least, and
> is not easily determinable, I think, whether or not that currently active
> Delaware company has any relationship whatsoever to the Secure Internet
> LLC to which ARIN issueed or assigned the set of IPv4 address blocks
> listed above.  What can be said is that ARIN issued or otherwise assigned
> the various IPv4 address blocks listed above to one or more companies
> using this exact name (Secure Internet, LLC) and that the relevant ARIN
> WHOIS records indicate a number of different mailing addresses, including
> mailing addresses in the State of Texas, another in Macau (China), another
> in the country of Belize, another in Bejing (China), and another in the
> State
> of New Jersey.  Among all of these diverse mailing addresses the one that
> appears most frequently in the records is:
>
> Address:        10685-B Hazelhurst Dr. #14783
> Address:        Houston, TX 77043 USA
> City:           Houston
> StateProv:      TX
> PostalCode:     77043
>
> This is an anonymous mailbox address.  The "#14783" is the specific box
> number.  I did not even need to google the remaining parts of the address
> as they are and were already known to me.  That specific mail handling
> company/facility is a long-time favorite of innumerable spammers.
>
> There is, at present, -no- company named Secure Internet, LLC which is
> legally registered to do business in -either- the State of Texas -or-
> the State of New Jersey.  I know of no easy way to check corporate
> registration status in the other relevant "offshore" jurisdictions.
>
> A majority of the relevant ARIN WHOIS records specifically mention
> GADIT3-ARIN and thus, by implication, a gentleman named Uzair Gadit.
> This seems to be a rather unique name.
>
> A gentleman having the exact name has a Facebook page where he lists
> himself as being a resident of Karachi, Pakistan:
>
>    https://www.facebook.com/uzair.gadit
>
> A separate online reference to a gentleman having the exact name indicates
> that he may currently reside in Dubai, U.A.E:
>
>    https://angel.co/uzair-gadit
>
> Regardless of where the specific "Secure Internet, LLC" to which ARIN has
> provided gobs and gobs of valuable IPv4 address is actually headquartered,
> and regadless of where the actual "main man" of that organization is
> presently residing, I, for one, am not at all happy to see an entire /17
> being trashed and wasted on hosting a large scale snowshoe spamming
> operation.  (And I am apparently not alone in this view.)  This is -not-
> in any sense an efficient use of such a limited resource, and I suspect
> that
> if the company was to undergo a usage audit today it would fail with flying
> colors.
>
> A number of factors add insult to injury in this case:
>
>    *)  Perhaps due to my own abundant ignorance, I have no understanding
>        of how this company could have amassed such a plethora of IPv4
>        blocks... ARIN-issued or otherwise... when it seems to be making
>        such poor, inefficient, and deplorable use of the ones it's got.
>
>    *) It is essentially and absolutely impossible to tell from any of
>       the relevant WHOIS records, combined with searches of relevant
>       Secretaries of State web sites, where this company is actually
>       headquartered.  Is it Texas?  New Jersey?  Delaware?  Belize?
>       U.A.E.?  Pakistan?  China perhaps?
>
>       (An even more interesting question: Is ARIN even allowed to tell me?
>       Or is even the mere jurisdiction of a registrant contractually a part
>       of the "confidential customer information" that ARIN agrees never to
>       disclose to any third party?)
>
>       I do quite a bit of this kind of research, and still I can say that
>       it is rare for me to come across quite such a slippery and ethereal
>       corporate entity as thi sone.  And the ARIN WHOIS records aren't
> making
>       it any easier to pin down just where the hell and/or what the hell
> this
>       thing actually is.  Is it a Delaware LLC?  A U.A.E. LLC?  Neither?
> Both?
>       I can't tell.  Nobody can.  This is not exactly my definition of
> "transparency"
>       and it isn't doing any favors for anybody seeking to find a
> responsible
>       party, either to report a case of serious ongoing high-level hacking
> /
>       network abuse or even just to helpfully inform the proprietors of the
>       company in question about some misconfiguration or other issue that
> they
>       may want to know about.
>
>    *) I openly admit to a certain degree of irrational and unjustifiable
>       xenophobia with respect to all this.  Mike Burns is competely correct
>       that if I get spammed, it hardly matters what region the relevant
>       provider got its IP addresses from, and even less what region the
>       proprietor of that provider happens to currently reside in.  But I am
>       nontheless offended to know that less than admirable actors from
> other
>       regions have used and are using what appear to be shell companies
> which
>       have then been used to acquire ARIN region resources that are then
> used
>       for other than admirable purposes.
>
>       Call me old fashioned, but if I'm going to be abused from ARIN-issued
>       resorces, then I think that the least I can ask is that 100% of the
>       profts derived therefrom should be going to North American Bad Actors
>       who can then create jobs and stimulate the economy right here in
> North
>       America.  I guess you might say that I'm totally down with our Cheeto
>       in Chief, specifically when it comes to his call to "Buy American".
>       If I have to endure being spammed from ARIN resources then I at least
>       want it to be all and only good North American spammers behind it,
>       rather than all of these darned foreigners.
>
> So, now that I've throughly vented my recent personal frustrations, is any
> of this fixable in a generalized sort of way that doesn't break everything
> else?
>
> Even if the answer is "no", I'd sill like to know how many people on this
> list are willing to sign my petition to build a wall and get RIPE to pay
> for it.  :-)
>
>
> Regards,
> rfg
>
>
> ------------------------------
>
> Message: 4
> Date: Tue, 17 Jul 2018 08:53:00 -0700
> From: Chris Woodfield <chris at semihuman.com>
> To: ARIN-PPML List <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Revised - Draft Policy ARIN-2018-4:
>         Clarification on IPv6 Sub-Assignments
> Message-ID: <7EBCF1B9-46A8-47E3-8B7C-5BDEA33D02E4 at semihuman.com>
> Content-Type: text/plain; charset="utf-8"
>
> Hello,
>
> Given the revision to this Draft Policy listed below, the AC is seeking
> community feedback on the revised policy text. Based on the initial
> discussion re: the original text, the following questions are key:
>
> - Is this problem statement relevant in light of the editorial change
> under consideration by the ARIN Board (formerly ARIN-2017-11)?
> https://www.arin.net/policy/proposals/2017_11.html <
> https://www.arin.net/policy/proposals/2017_11.html>
>
> - Does the removal of specific use cases not considered assignments result
> in workable text, or does the community feel that the new language is too
> broad?
>
> Thanks,
>
> -Chris
>
> > On Jul 16, 2018, at 11:45 AM, ARIN <info at arin.net> wrote:
> >
> > The following has been revised:
> >
> > * Draft Policy ARIN-2018-4: Clarification on IPv6 Sub-Assignments
> >
> > Revised text is below and can be found at:
> > https://www.arin.net/policy/proposals/2018_4.html
> >
> > You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion in order to assess the conformance of this draft
> policy with ARIN's Principles of Internet number resource policy as stated
> in the Policy Development Process (PDP). Specifically, these principles are:
> >
> > * Enabling Fair and Impartial Number Resource Administration
> > * Technically Sound
> > * Supported by the Community
> >
> > The PDP can be found at:
> > https://www.arin.net/policy/pdp.html
> >
> > Draft Policies and Proposals under discussion can be found at:
> > https://www.arin.net/policy/proposals/index.html
> >
> > Regards,
> >
> > Sean Hopkins
> > Policy Analyst
> > American Registry for Internet Numbers (ARIN)
> >
> >
> >
> > Draft Policy ARIN-2018-4: Clarification on IPv6 Sub-Assignments
> >
> > Problem Statement:
> >
> > When the policy was drafted, the concept of assignments/sub-assignments
> did not consider the use of IP addresses in hotspots, or the use of IP
> addresses by guests or employees in Bring Your Own Device (BYOD) and many
> other similar cases.
> >
> > Additionally, the IETF has recently approved the use of a unique /64
> prefix per interface/host (RFC8273) instead of a unique address. This, for
> example, allows users to connect to a hotspot, receive a /64 such that they
> are "isolated" from other users (for reasons of security, regulatory
> requirements, etc.) and they can also use multiple virtual machines on
> their devices with a unique address for each one (within the same /64).
> >
> > Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such
> assignments, stating that "Assignments... are not to be sub-assigned to
> other parties".
> >
> > This proposal clarifies this situation in this regard and better define
> the concept, particularly considering new uses of IPv6 (RFC8273), by means
> of a new paragraph.
> >
> > Note that the proposal text also incorporates changes made under an
> Editorial Change currently awaiting Board of Trustees review, available
> here: https://www.arin.net/policy/proposals/2017_11.html
> >
> > Policy Statement:
> >
> > Actual Text, Section 2.5:
> >
> > ?    Assign - To assign means to delegate address space to an ISP or
> end-user, for specific use within the Internet infrastructure they operate.
> Assignments must only be made for specific purposes documented by specific
> organizations and are not to be sub-assigned to other parties.
> >
> > New Text:
> >
> > ?   Assignment - Address space delegated to an organization directly by
> ARIN for the exclusive use of the recipient organization. A temporary
> assignment of address space provided to third parties shall not be
> considered an assignment.
> >
> > Comments
> >
> > Timetable for implementation:
> >
> > Immediate
> >
> > Anything else:
> >
> > Situation in other regions:
> >
> > This situation, has already been corrected in RIPE, and the policy was
> updated in a similar way, even if right now there is a small discrepancy
> between the policy text that reached consensus and the RIPE NCC Impact
> Analysis. A new policy proposal has been submitted to amend that, and the
> text is the same as presented by this proposal at ARIN. Same text has also
> been submitted to AfriNIC, LACNIC and APNIC.
> > _______________________________________________
> > ARIN-PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > https://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
>
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