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

[John Curran]

Tyler - 

	In all cases, ARIN’s customer remains the ISP that is doing reassignment/reallocation.

	While ARIN provides some services to those receiving reassignments/reallocations,
	those services are provided at the behest of the ISP. 

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers


> On Jun 4, 2025, at 11:10 AM, Tyler O'Meara <arin at tyleromeara.com> wrote:
> 
> 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
>>>> 
>>>> 
>>>> 
>>>> 
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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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