[arin-ppml] Draft Policy ARIN-2019-2: Waiting List Block Size Restriction

hostmaster at uneedus.com hostmaster at uneedus.com
Thu Feb 28 21:13:33 EST 2019

I was merely proposing making the requirements tougher.  The no tax cheat 
requirement is not in the current policy manual.

In addition to the ones that are being caught, because of their attempt to 
transfer out the numbers to someone else, I venture to guess part of the 
remainder might be others who informally sell/lease the numbers, or are 
agents of another who is attempting to gather a block of addresses a /22 
or more at a time without having to go into the marketplace and buy them. 
They might also simply give the buyer control of the shell company, and 
the contacts at ARIN might be a common email domain like Gmail and Google 
voice that is turned over to the buyer. Since nothing changes at ARIN, it 
is not noticed.  This might mean the problem is even larger.

As for shell corporations, I strongly suspect that bad actors are mostly 
using freshly minted ones. I propose a requirement that a corporation 
exist for 3 years before being assigned numbers in its own name which 
could greatly reduce fraud.  Younger corportations would have to hold 
space in trust for the corporation in the names of the top shareholders 
for the first 3 years.  This would help identify bad actors if the same 
names keep being used again and again.

I think that the policies should also require anyone receiving waiting 
list space or section 8 transfers to have active IPv6 connections, and an 
active allocation of IPv6. This would further promote the use of IPv6, a 
desired goal. I believe all these issues will go away once IPv6 becomes 
the primary transport of the internet, and there is no shortage of 
numbers. We did not have this problem when there was not a number 

As for ICANN, I have been filing whois unavailable complaints for those 
registrars without IPv6 connectivity, as this has been a requirement since 
2013, and I still find registrars without it. It does take a few weeks, 
but they do enforce whois rules and IPv6 whois always seems to appear....

I am very glad that ARIN staff is watching out for these transfer outs. 
For actual companies that need the space from the marketplace or waiting 
list, it would be highly unusual for them to sell space after going thru 
the trouble to get space.  That activity is clearly a red flag.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 28 Feb 2019, Ronald F. Guilmette wrote:

> In message <Pine.LNX.4.64.1902280622220.21254 at localhost.localdomain>,
> hostmaster at uneedus.com wrote:
>> Why is it that this language on M&As not strong enough?  Having to show a
>> balance sheet of assets and liabilities certifed by a CPA would certainly
>> show if it is simply a IP address shell company.  If there are no
>> certified statements, it kinda means that company is likely a tax cheat,
>> and ARIN should not do business with them.
> Two questions:
> First, may I quote you?  I mean elsewhere.
> Second, could you please point me at the section of the ARIN Policy manual
> that prohibits ARIN from doing business with any or all "likely tax cheats"?
> I'm real eager to see that, because I'd like to propse to ICANN that it
> also should incorporate some such language into its own policies and
> procedures with respect to its formally accredited domain name registrars.
> I've been specifically looking at an ICANN Accredited Doamin Name
> registrar called NameCheap which has, over time, appeared to have more
> than its fair share of abusive domain name registrations.  The company
> has claimed at different times to be domiciled in either California or
> Arizona, and yet after a resonable search I have been unable to find
> any evidence of it having ever been formally incorporated in either state.
> If it never formally registered as a resident business in either state,
> then one might reasonably assume that, pragmatically speaking, it simply
> could never have paid any state-level taxes in either state because it
> simply never had a state business registration number in either state
> of the kind that would be necessary to file a return in those states.
> I've asked the company about this via email, and they have not responded.
> I've also asked some other folks about this and I've been told that it
> is not ICANN's job to try to figure out which of their accredited domain
> name registrars are likely tax cheats.  (Apparently, to paraphrase that
> old adage, ICANN "is not the tax police".)
> I can't help but think that this general rule applies also in the case
> of ARIN.  ARIN also is not the tax police.
> Regards,
> rfg
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