[arin-ppml] distributing resources for individuals

Fri Apr 18 12:42:20 EDT 2025

In my view, Secretary of State (SOS) registration is an easy button for
ARIN, and when available, that's fine. Nevertheless, I also expect ARIN to
have processes and procedures in place when the SOS option is not
available. A sole proprietorship that is not registered with the SOS is
still a valid business in many states, and ARIN needs processes and
procedures in place to deal with that situation.

Earlier, I referenced Section 9 and the flexibility in determining that an
organization is operating in the ARIN; similar flexibility is needed in
determining whether an individual is operating as a business. I'll also
note that Section 9 is quite clear: registration in the ARIN region alone
is not sufficient to determine whether an organization is operating in the
ARIN region. Similarly, a lack of registration alone should not be
sufficient to find that an individual is not operating as a business.

As to ARIN policy, it predominantly references organizations. Individuals
only come up in the context of defining a Residential Customer. With that
context, ARIN policy strongly assumes LIRs, ISPs, and end-users are
organizations, not individuals.

Thanks.

On Fri, Apr 18, 2025 at 11:05 AM Owen DeLong <owen at delong.com> wrote:

> Not all states will register a sole proprietorship under a person’s legal
> name, making it difficult for some sole proprietorships to clear ARIN’s
> current requirements. Worse, individuals and sole proprietors who know
> which buttons to push on the ARIN staff seem to be able to get ORG-IDs
> without SOS registration while others seem to get rejected on that basis.
>
> I’m not arguing that these “exceptions” should go away, I’m arguing that
> they should be more widely available and perhaps it is time to drop the
> “organization” pretext altogether.
>
> Owen
>
>
> On Apr 17, 2025, at 17:54, David Farmer via ARIN-PPML <arin-ppml at arin.net>
> wrote:
>
> 
> Ok, natural persons can be RIPE members in their own right, I guess I was
> wrong, but you pay €1,800 for membership.  Where as with ARIN you start at
> $250, even with potential state registration fees for a sole
> proprietorship, you probably still come out well ahead.
>
> On Thu, Apr 17, 2025 at 19:43 David Farmer <farmer at umn.edu> wrote:
>
>> Out of curiosity can you point me to the agreement on RIPE’s web site.
>>
>> Thanks
>>
>> On Thu, Apr 17, 2025 at 19:38 Ryan Hamel <ryan at rkhtech.org> wrote:
>>
>>> David,
>>>
>>> I signed an agreement with RIPE NCC, have an account in their portal,
>>> and had an ASN + IPv6 assignment...
>>>
>>> Kind regards,
>>>
>>> Ryan Hamel
>>> ------------------------------
>>> *From:* ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of David
>>> Farmer via ARIN-PPML <arin-ppml at arin.net>
>>> *Sent:* Thursday, April 17, 2025 6:35:37 PM
>>> *To:* John Curran <jcurran at arin.net>
>>> *Cc:* Preston Ursini <preston at thefirehorn.com>; arin-ppml at arin.net <
>>> arin-ppml at arin.net>
>>> *Subject:* Re: [arin-ppml] distributing resources for individuals
>>>
>>> Caution: This is an external email and may be malicious. Please take
>>> care when clicking links or opening attachments.
>>>
>>> First, my understanding is that individuals don't get resources from
>>> RIPE either; Member Organizations do. You, as an individual, get
>>> resources from an LIR that is a RIPE Member, and the LIR gets the
>>> resources from RIPE, maintains the relationship with RIPE, and assigns
>>> them to you. As an individual, your relationship is with the LIR, not RIPE,
>>> unless I'm completely misunderstanding RIPE's policies and business
>>> practices.
>>>
>>> A similar arrangement could be facilitated by an LIR (also known as an
>>> ISP) that is an ARIN Member Organization. That isn't as common a practice
>>> here in the ARIN Region. ARIN has a lower barrier to entry and deals
>>> directly with end-user organizations, but not end-users as individuals.
>>>
>>> Thanks.
>>>
>>> On Thu, Apr 17, 2025 at 6:51 PM John Curran <jcurran at arin.net> wrote:
>>>
>>> Preston -
>>>
>>> I don’t think any of the present discussion has been predicated on fraud
>>> concerns.
>>>
>>> (Note that ARIN currently has some extensive anti-fraud practices that
>>> include various forms of government issued ID presentation and
>>> verification.)
>>>
>>> Thanks,
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>>
>>> On Apr 17, 2025, at 7:39 PM, Preston Ursini <preston at thefirehorn.com>
>>> wrote:
>>>
>>> Would I be correct in that there hasn’t been an actually policy proposal
>>> submitted for this?
>>>
>>> I believe that whether or not this new policy were to be considered,
>>> that a copy of a government issued identification document be submitted to
>>> the person signing the Registration Services Agreement whenever an OrgID is
>>> issued.  This can help immensely in tracking down fraud which seems to be a
>>> pillar concern.
>>>
>>> For simplicity sake, I’d also say in any such policy allowing an
>>> Individual to obtain numbering assets simply be issued an OrgID just as
>>> sole proprietors are as to minimize disruption to ARIN operations in
>>> implementing this policy.
>>>
>>>
>>> Preston Ursini
>>>
>>>
>>> On Apr 17, 2025, at 6:28 PM, John Curran <jcurran at arin.net> wrote:
>>>
>>> Preston -
>>>
>>> That’s a reasonable question (“why an individual cannot be accepted as
>>> they are generally the same legal entity…”)
>>>
>>> You’re right that a sole proprietorship is legally tied to the
>>> individual behind it, but that doesn’t make it the same as issuing
>>> resources to individuals.  At the time of ARIN’s formation (and for a
>>> suibstantial period before), number resources were issued to organizations.
>>> The old netnumber.txt request forms made that clear, asking for “the
>>> organization responsible for establishing the network” along with a postal
>>> address. That model is what ARIN inherited when it was formed in 1997, and
>>> it’s what we continue to operate under.
>>>
>>> While it’s true in theory that ARIN could adopt a model where it
>>> directly serves individuals, this would represent a significant departure
>>> from the registry model we inherited and have operated under for decades.
>>> Even though individuals and organizations can both be “legal entities,”
>>> that does not mean they are treated identically under law. For example,
>>> companies that predominantly focus on serving businesses (often referred to
>>> as B2B) are often subject to different laws, regulations, and tax policy
>>> than those that hold themselves out to serve individuals. Thus, shifting to
>>> a model that openly includes individuals could have significant unintended
>>> implications for ARIN.
>>>
>>> That doesn’t mean it can’t be done, but it would be important to
>>> understand the problem that such a change would solve. ARIN accepts
>>> incorporated entities, DBAs, sole proprietors, etc.—because we know
>>> networks are run by all kinds of operators. But in every case, we’re still
>>> issuing to an organization, however minimal the structure might be.
>>>
>>> Thanks!
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>> On Apr 17, 2025, at 2:09 PM, Preston Ursini via ARIN-PPML <
>>> arin-ppml at arin.net> wrote:
>>>
>>> If a sole proprietorship is accepted, I am confused as to why an
>>> Individual cannot be accepted as they are generally the same legal entity
>>> unless it is an individual?
>>>
>>> There are over 20,000 political subdivisions within the United States
>>> when you count cities, counties, townships, etc., all with their own rules
>>> when it comes to business licenses and conducting business, trying to tie
>>> every sole proprietorship down with a business license when one may not be
>>> required in many of these jurisdictions seems strange at best.
>>>
>>> In general the law sees Corporations and Individuals as all in the same,
>>> so I’m a little confused as to why ARIN would be ok with doing business
>>> with a sole proprietor but not an "individual"?
>>>
>>> If the issue is fraud prevention, it seems like a better approach would
>>> be tying all accounts regardless of whether it is a business/individual,
>>> with a government issued identification document; the trend with having an
>>> officer of a company sign an RSA seems to be a step in the direction in
>>> tying real people to accounts; assuming the goal here is to ensure
>>> accountability for resource allocation?
>>>
>>>
>>>
>>> Preston Ursini
>>>
>>>
>>> On Apr 17, 2025, at 7:21 AM, arin-ppml-request at arin.net wrote:
>>>
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>>>
>>>
>>> Today's Topics:
>>>
>>> 1. Re: distributing resources for individuals
>>>    (jordi.palet at consulintel.es)
>>> 2. Re: distributing resources for individuals (John Curran)
>>>
>>>
>>> ----------------------------------------------------------------------
>>>
>>> Message: 1
>>> Date: Thu, 17 Apr 2025 09:00:26 +0200
>>> From: "jordi.palet at consulintel.es" <jordi.palet at consulintel.es>
>>> To: arin-ppml <arin-ppml at arin.net>
>>> Subject: Re: [arin-ppml] distributing resources for individuals
>>> Message-ID: <9175FF4A-94C3-4021-96CE-44AC5D1DA382 at consulintel.es>
>>> Content-Type: text/plain; charset="utf-8"
>>>
>>> Hi John,
>>>
>>> A couple of questions on this:
>>>
>>> 1) There is a formal confirmation that this ?simple and ?inexpensive?
>>> procedure is the same in all the ?areas? (states, whatever is te division
>>> in each country) for all the service region countries of ARIN?
>>>
>>> 2) Are we sure that in all those areas/countries the cost of keeping
>>> that ?status? (the one that is valid for ARIN), and I mean not only money,
>>> but also recurrent paperwork (like for example if you need to present
>>> quarterly/yearly tax reports, even if you don?t had economical activity),
>>> is close to ?zero"?
>>>
>>> 3) As 1 and 2 above may change (a country law may decide that a
>>> sole-proprietorship may be enforced to something else much more expensive
>>> or cease that status), do it make sense that the policy and/or membership
>>> documents ask for something that doesn?t depend on ARIN decisions, instead
>>> of relaying in making sure that you provide ?real documents? and of course
>>> a valid justification for the resources that you request (which is already
>>> set in the policies for each type of resource)?
>>>
>>> Regards,
>>> Jordi
>>>
>>> @jordipalet
>>>
>>>
>>> El 17 abr 2025, a las 2:34, John Curran <jcurran at arin.net> escribi?:
>>>
>>> Ryan -
>>>
>>> Indeed.  As both myself (and Bill Herrin) have pointed out a few times
>>> in this discussion,  ARIN already has flexibility in this regard and we do
>>> have sole proprietorships that enter into agreements and obtain number
>>> resources.  Sole proprietorship works, DBA name registration works,
>>> incorporation of a legal entity works ? hence the reason for further
>>> discussion in order to gain a better understanding of the problem to be
>>> solved.
>>>
>>> Thanks,
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>>
>>> On Apr 16, 2025, at 8:16?PM, Ryan Hamel <ryan at rkhtech.org> wrote:
>>>
>>> John,
>>>
>>> I echo David's point coming from California. My ARIN resources are under
>>> my legal name, which was approved by the team that handles org tickets, and
>>> the legal team.
>>>
>>> A sole proprietor without a DBA, can legally conduct business in several
>>> states and potentially provinces too, and that also includes signing ARIN's
>>> agreements.
>>>
>>> Kind regards,
>>>
>>> Ryan Hamel
>>> From: ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of David Farmer
>>> via ARIN-PPML <arin-ppml at arin.net>
>>> Sent: Wednesday, April 16, 2025 4:58:48 PM
>>> To: John Curran <jcurran at arin.net>
>>> Cc: arin-ppml <arin-ppml at arin.net>
>>> Subject: Re: [arin-ppml] distributing resources for individuals
>>>
>>> Caution: This is an external email and may be malicious. Please take
>>> care when clicking links or opening attachments.
>>>
>>> John,
>>>
>>> The issue is in Missouri, Minnesota, and probably many other states; if
>>> you are doing business under your own name and not a DBA, you don't need to
>>> register with the state to operate a sole proprietorship.
>>>
>>> So, if ARIN procedures require a lookup with the Secretary of State,
>>> effectively, that requires more than just operating as a business; it also
>>> requires operating that business under a fictitious name, not under the
>>> owner's name.
>>>
>>> Section 9 of the NRPM gives a lot of latitude for demonstrating that an
>>> organization operates within the ARIN region. A similar amount of latitude
>>> should be available to establish that an individual is acting as a business
>>> and not an individual, even if the jurisdiction's laws and procedures don't
>>> neatly align with ARIN procedures.
>>>
>>> Thanks
>>>
>>> On Wed, Apr 16, 2025 at 6:04?PM John Curran <jcurran at arin.net <mailto:
>>> jcurran at arin.net>> wrote:
>>>
>>>
>>> On Apr 16, 2025, at 6:02?PM, Paul E McNary <pmcnary at cameron.net <mailto:
>>> pmcnary at cameron.net>> wrote:
>>>
>>> Originally
>>> 12 years ago when I tried to get ARIN resources, I was greatly harmed by
>>> this.
>>> In Missouri at that time a Sole Proprietor did not have to register with
>>> the Secretary of State.
>>> ARIN would not issue resources unless they could verify you with
>>> Secretary of State database.
>>> We had a State Sales Tax and Employment Tax ID for 20 years, but that
>>> wasn't good enough.
>>>
>>>
>>> Paul -
>>>
>>> To be certain there?s a clear understanding of the problem that resulted
>>> from the organization requirement ? are you saying that you were unable to
>>> register a DBA name with Missouri Secretary of State in 2013?  There is a
>>> 7$ fee associated with such registration (every 5 years) but from all
>>> appearances it is otherwise a rather nominal process, so if there is/was
>>> some other barrier it would be good to explain it so that folks understand
>>> the scope of the problem that you experienced when trying to do so.
>>>
>>> Thanks,
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>>
>>> _______________________________________________
>>> 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.
>>>
>>>
>>>
>>>
>>> **********************************************
>>> IPv4 is over
>>> Are you ready for the new Internet ?
>>> http://www.theipv6company.com
>>> The IPv6 Company
>>>
>>> This electronic message contains information which may be privileged or
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>>> disclosure, copying, distribution or use of the contents of this
>>> information, even if partially, including attached files, is strictly
>>> prohibited and will be considered a criminal offense. If you are not the
>>> intended recipient be aware that any disclosure, copying, distribution or
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>>> ------------------------------
>>>
>>> Message: 2
>>> Date: Thu, 17 Apr 2025 12:21:30 +0000
>>> From: John Curran <jcurran at arin.net>
>>> To: "jordi.palet at consulintel.es" <jordi.palet at consulintel.es>
>>> Cc: arin-ppml <arin-ppml at arin.net>
>>> Subject: Re: [arin-ppml] distributing resources for individuals
>>> Message-ID: <19584E59-969A-4EC3-BB29-6500464AF949 at arin.net>
>>> Content-Type: text/plain; charset="utf-8"
>>>
>>> Jordi -
>>>
>>> The representation you seek from ARIN regarding government procedures
>>> across the the entire region is not possible to make ? and as you note, it
>>> would be meaningless the very next day because such laws and regulations
>>> are outside of ARIN?s control and subject to change.  Note that this is the
>>> case regardless of whether speaking of networks run by organizations or
>>> individuals ? the legal requirements on networks in any given portion of
>>> the ARIN region are not determined by ARIN.
>>>
>>> What we can say is that our customers want us to be reasonably flexible
>>> in our processes to the extent possible, just as we are with respect to
>>> confirming whether organizations requesting resources operate within the
>>> ARIN region.  We?ve evolved our processes over time to make be more
>>> straightforward, and this includes handling entities that are incorporated,
>>> those using DBA registrations, sole proprietorships, etc.
>>>
>>> Your original query noted that ? In LACNIC we are having a discussion
>>> because the policy manual only allows to distribute resources to
>>> ?organizations legally registered? ? ? To be clear, ARIN is effectively the
>>> same, but we are quite flexible in recognition of how our network customers
>>> may go about their legal registration.
>>>
>>> Thanks!
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>> On Apr 17, 2025, at 3:00?AM, jordi.palet--- via ARIN-PPML <
>>> arin-ppml at arin.net> wrote:
>>>
>>> Hi John,
>>>
>>> A couple of questions on this:
>>>
>>> 1) There is a formal confirmation that this ?simple and ?inexpensive?
>>> procedure is the same in all the ?areas? (states, whatever is te division
>>> in each country) for all the service region countries of ARIN?
>>>
>>> 2) Are we sure that in all those areas/countries the cost of keeping
>>> that ?status? (the one that is valid for ARIN), and I mean not only money,
>>> but also recurrent paperwork (like for example if you need to present
>>> quarterly/yearly tax reports, even if you don?t had economical activity),
>>> is close to ?zero"?
>>>
>>> 3) As 1 and 2 above may change (a country law may decide that a
>>> sole-proprietorship may be enforced to something else much more expensive
>>> or cease that status), do it make sense that the policy and/or membership
>>> documents ask for something that doesn?t depend on ARIN decisions, instead
>>> of relaying in making sure that you provide ?real documents? and of course
>>> a valid justification for the resources that you request (which is already
>>> set in the policies for each type of resource)?
>>>
>>> Regards,
>>> Jordi
>>>
>>> @jordipalet
>>>
>>>
>>> El 17 abr 2025, a las 2:34, John Curran <jcurran at arin.net> escribi?:
>>>
>>> Ryan -
>>>
>>> Indeed.  As both myself (and Bill Herrin) have pointed out a few times
>>> in this discussion,  ARIN already has flexibility in this regard and we do
>>> have sole proprietorships that enter into agreements and obtain number
>>> resources.  Sole proprietorship works, DBA name registration works,
>>> incorporation of a legal entity works ? hence the reason for further
>>> discussion in order to gain a better understanding of the problem to be
>>> solved.
>>>
>>> Thanks,
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>>
>>> On Apr 16, 2025, at 8:16?PM, Ryan Hamel <ryan at rkhtech.org> wrote:
>>>
>>> John,
>>>
>>> I echo David's point coming from California. My ARIN resources are under
>>> my legal name, which was approved by the team that handles org tickets, and
>>> the legal team.
>>>
>>> A sole proprietor without a DBA, can legally conduct business in several
>>> states and potentially provinces too, and that also includes signing ARIN's
>>> agreements.
>>>
>>> Kind regards,
>>>
>>> Ryan Hamel
>>> ________________________________
>>> From: ARIN-PPML <arin-ppml-bounces at arin.net> on behalf of David Farmer
>>> via ARIN-PPML <arin-ppml at arin.net>
>>> Sent: Wednesday, April 16, 2025 4:58:48 PM
>>> To: John Curran <jcurran at arin.net>
>>> Cc: arin-ppml <arin-ppml at arin.net>
>>> Subject: Re: [arin-ppml] distributing resources for individuals
>>>
>>> Caution: This is an external email and may be malicious. Please take
>>> care when clicking links or opening attachments.
>>>
>>> John,
>>>
>>> The issue is in Missouri, Minnesota, and probably many other states; if
>>> you are doing business under your own name and not a DBA, you don't need to
>>> register with the state to operate a sole proprietorship.
>>>
>>> So, if ARIN procedures require a lookup with the Secretary of State,
>>> effectively, that requires more than just operating as a business; it also
>>> requires operating that business under a fictitious name, not under the
>>> owner's name.
>>>
>>> Section 9 of the NRPM gives a lot of latitude for demonstrating that an
>>> organization operates within the ARIN region. A similar amount of latitude
>>> should be available to establish that an individual is acting as a business
>>> and not an individual, even if the jurisdiction's laws and procedures don't
>>> neatly align with ARIN procedures.
>>>
>>> Thanks
>>>
>>> On Wed, Apr 16, 2025 at 6:04?PM John Curran <jcurran at arin.net<mailto:
>>> jcurran at arin.net>> wrote:
>>>
>>>
>>> On Apr 16, 2025, at 6:02?PM, Paul E McNary <pmcnary at cameron.net<mailto:
>>> pmcnary at cameron.net>> wrote:
>>>
>>> Originally
>>> 12 years ago when I tried to get ARIN resources, I was greatly harmed by
>>> this.
>>> In Missouri at that time a Sole Proprietor did not have to register with
>>> the Secretary of State.
>>> ARIN would not issue resources unless they could verify you with
>>> Secretary of State database.
>>> We had a State Sales Tax and Employment Tax ID for 20 years, but that
>>> wasn't good enough.
>>>
>>> Paul -
>>>
>>> To be certain there?s a clear understanding of the problem that resulted
>>> from the organization requirement ? are you saying that you were unable to
>>> register a DBA name with Missouri Secretary of State in 2013?  There is a
>>> 7$ fee associated with such registration (every 5 years) but from all
>>> appearances it is otherwise a rather nominal process, so if there is/was
>>> some other barrier it would be good to explain it so that folks understand
>>> the scope of the problem that you experienced when trying to do so.
>>>
>>> Thanks,
>>> /John
>>>
>>> John Curran
>>> President and CEO
>>> American Registry for Internet Numbers
>>>
>>>
>>> _______________________________________________
>>> 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.
>>>
>>>
>>> **********************************************
>>> IPv4 is over
>>> Are you ready for the new Internet ?
>>> http://www.theipv6company.com
>>> The IPv6 Company
>>>
>>> This electronic message contains information which may be privileged or
>>> confidential. The information is intended to be for the exclusive use of
>>> the individual(s) named above and further non-explicilty authorized
>>> disclosure, copying, distribution or use of the contents of this
>>> information, even if partially, including attached files, is strictly
>>> prohibited and will be considered a criminal offense. If you are not the
>>> intended recipient be aware that any disclosure, copying, distribution or
>>> use of the contents of this information, even if partially, including
>>> attached files, is strictly prohibited, will be considered a criminal
>>> offense, so you must reply to the original sender to inform about this
>>> communication and delete it.
>>>
>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
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>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
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>>> _______________________________________________
>>> ARIN-PPML
>>> You are receiving this message because you are subscribed to
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>>> Please contact info at arin.net if you experience any issues.
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>>>
>>>
>>>
>>> --
>>> ===============================================
>>> David Farmer               Email:farmer at umn.edu
>>> Networking & Telecommunication Services
>>> Office of Information Technology
>>> University of Minnesota
>>> 2218 University Ave SE
>>> <https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g>
>>>       Phone: 612-626-0815
>>> Minneapolis, MN 55414-3029   Cell: 612-812-9952
>>> ===============================================
>>>
>> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
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>

-- 
===============================================
David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===============================================
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