[arin-ppml] Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons

[Tyler O'Meara]

Hi John,

That's rather surprising. How do concerns 1-3 in the legal analysis not apply in
the case of a detailed reassignment, given that ARIN charges for Org creations?
Is there some special legal treatment for the org create transaction that
doesn't apply to the resource issuance transactions? Further, since these OrgIDs
exist in WHOIS (and ARIN is handling the private data for a non-business natural
person), is there some legal reason concern 4 only applies to direct
allocations? Lastly, given that the natural person is signing the RSA, I would
expect that concern 6 would also apply, albeit with a more narrow scope since
the resources ultimatley don't "belong" to the natural person in question.

To be clear, I am not a lawyer and I am not second guessing the legal analysis
of lawyers. I'm just trying to get a better understanding of how and why direct
assignments are legally distinct from detailed reassignments.

This is actually a very interesting line of questioning, thanks for raising it
David.

As a thought exercise (and I am NOT suggesting this for real), could we work
around the legal issues by adopting a sponsoring LIR model similar to RIPE's,
where only business entities may receive direct allocations, but they may
request resources on behalf of non-business entities and then reassign them to
those entities? Would we be able to allow LIR portability such that the non-
business entity has "ownership" over the resources, and can switch between
sponsors as needed?

Thanks,
Tyler

On Wed, 2025-06-04 at 14:39 +0000, John Curran wrote:
> David –
> 
> An excellent question indeed.   
> 
> ARIN does not limit who can receive a simple or detailed reassignment.   For
> detailed reassignment, we will have them sign an RSA and create an OrgID for
> party (allowing them to use services such as IRR), but the resources remain
> ultimately under control of the ISP doing the reassignment, and that ISP is
> ARIN's customer. 
> 
> Thanks!
> /John
> 
> 
> 
> John Curran
> President and CEO
> American Registry for Internet Numbers
> 
> 
> > On Jun 3, 2025, at 11:11 PM, David Farmer <farmer at umn.edu> wrote:
> > 
> > 
> > 
> > John,
> > 
> > Thanks to the ARIN Staff and you for the detailed staff and legal review; it
> > defines the problem well.
> > 
> > I have a related question about organizations from a slightly
> > different angle than direct allocations made by ARIN.
> > 
> > Considering reassignments and reallocations and their interactions with
> > organizations in the database, particularly when creating an Org ID or an
> > organization within the database to receive a reassignment or reallocation.
> > Are natural persons not operating a business allowed to be listed as an
> > organization solely for obtaining a detailed reassignment or reallocation?
> > Or are natural persons not operating a business effectively limited to
> > receiving a simple reassignment instead, because to be an organization, at
> > least for a direct allocation from ARIN, a natural person must be operating
> > a business? 
> > 
> > It seems unlikely that allowing natural persons to receive a reassignment or
> > reallocation would impact ARIN's B2B operational status, whereas a direct
> > allocation from ARIN would.
> > 
> > Thanks.
> > 
> > Thnaks
> > 
> > 
> >  facilitate a detailed reassignment do curenet procedures 
> > 
> > 
> > 
> > On Tue, Jun 3, 2025 at 7:39 PM John Curran <jcurran at arin.net> wrote:
> > > Folks - 
> > > 
> > > The (initial)  staff and legal review for Draft Policy ARIN-2025-4 is
> > > available online in the Policy section of the ARIN website.
> > > 
> > > Direct link -
> > > <https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-re
> > > view-3-june-2025>
> > > 
> > > FYI,
> > > /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.
> > > 
> > 
> > 
> > -- 
> > ===============================================
> > 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
> > =============================================== 
> 
> _______________________________________________
> 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.