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<DIV><FONT size=2 face=Arial>Hi Owen,</FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial>I'm top-posting because it's too hard to keep this
readable with the black vertical lines on the left side.</FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial>I guess we can let Geoff Huston speak for
himself:</FONT></DIV>
<DIV><FONT size=2 face=Arial><A
href="http://www.potaroo.net/ispcol/2008-11/transfers.html">http://www.potaroo.net/ispcol/2008-11/transfers.html</A></FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial>As to Microsoft planning leading them to purchasing
the same exact need as ARIN's particular application of its policies at the time
of the transaction?</FONT></DIV>
<DIV><FONT size=2 face=Arial>Please.</FONT></DIV>
<DIV><FONT size=2 face=Arial>Remember that Microsoft was an arms-length
negotiator who was solicited by the address broker in the deal along with 80
other companies.</FONT></DIV>
<DIV><FONT size=2 face=Arial>So Microsoft's planning was so excellent that they
could find the exact amount of addresses they needed in the form of the very
first public sale of legacy addresses ever recorded?</FONT></DIV>
<DIV><FONT size=2 face=Arial>That's believable!</FONT></DIV>
<DIV><FONT size=2 face=Arial>And their excellent planning staff, whose decision
so exactly matched ARIN's ex-post-facto analysis, failed to inform management
that they could save $7.5 million by getting them directly from
ARIN?</FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial><FONT size=3 face="Times New Roman"> "I
suppose since I favor a faster migration to IPv6, I should probably support
</FONT>the greater disruption to IPv4 brought about by your policy, but, in the
interests of the community, I just can't bring myself to do so."</FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial>lol. Sounds like you're shirking your longterm
stewardship duties there.</FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial>Regards,</FONT></DIV>
<DIV><FONT size=2 face=Arial>Mike</FONT></DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<DIV><FONT size=2 face=Arial></FONT> </DIV>
<BLOCKQUOTE
style="BORDER-LEFT: #000000 2px solid; PADDING-LEFT: 5px; PADDING-RIGHT: 0px; MARGIN-LEFT: 5px; MARGIN-RIGHT: 0px"
dir=ltr>
<DIV style="FONT: 10pt arial">----- Original Message ----- </DIV>
<DIV
style="FONT: 10pt arial; BACKGROUND: #e4e4e4; font-color: black"><B>From:</B>
<A title=owen@delong.com href="mailto:owen@delong.com">Owen DeLong</A> </DIV>
<DIV style="FONT: 10pt arial"><B>To:</B> <A title=mike@nationwideinc.com
href="mailto:mike@nationwideinc.com">Mike Burns</A> </DIV>
<DIV style="FONT: 10pt arial"><B>Cc:</B> <A title=john.sweeting@twcable.com
href="mailto:john.sweeting@twcable.com">Sweeting, John</A> ; <A
title=arin-ppml@arin.net
href="mailto:arin-ppml@arin.net">arin-ppml@arin.net</A> </DIV>
<DIV style="FONT: 10pt arial"><B>Sent:</B> Thursday, May 19, 2011 12:45
PM</DIV>
<DIV style="FONT: 10pt arial"><B>Subject:</B> Re: [arin-ppml] IPv4 Transfer
Policy Change to Keep Whois Accurate</DIV>
<DIV><BR></DIV><BR>
<DIV>
<DIV>On May 19, 2011, at 7:59 AM, Mike Burns wrote:</DIV><BR
class=Apple-interchange-newline>
<BLOCKQUOTE type="cite">
<DIV>Hi Owen,<BR><BR>
<BLOCKQUOTE type="cite">You also left off:<BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">4. It might actually reduce whois accuracy rather
than increase it.<BR></BLOCKQUOTE><BR>Why does anybody think that removing
the needs requirement for transfers would degrade whois
accuracy?<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Because that is exactly what happened to DNS whois when
stewardship was abandoned there in favor</DIV>
<DIV>of an uncontrolled market.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>The only support for that contention was the idea that because the
needs requirement involved some extra informational flow, the contact
information would be more accurate.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>No, that was ONE element of support and I believe it holds
true.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>I argue that registration will become more and more important, and John
Curran indicated there was an uptick in 8.2 Transfers for old M&A
activity, which I held to be an indication that holders of addresses find
registration valuable, and likely more so as the addresses increase in
monetary value.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Which would argue that removing needs basis will not improve
that situation.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>People will naturally want their ownership rights established in
whatever venue is appropriate, and for ip address holdings, that venue is
Whois.<BR>I don't think the argument that my proposal will reduce Whois
accuracy holds water, is there anybody who wants to continue to make that
charge?<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>
<DIV>I will continue to make the charge that it is one possible outcome and
just as likely as any claim that your proposal could somehow</DIV>
<DIV>improve it.</DIV>
<DIV><BR></DIV>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">5. Markets without additional controls inevitably
lead to manipulation and dysfunction<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">which requires later regulation to correct. These
later corrections are rarely (if ever)<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">effective at making the original victims of the
manipulations and dysfunction whole.<BR></BLOCKQUOTE><BR>First, this is
your opinion only, second, I already alluded to speculators and
hoarders, and your number 5 is merely a restatement.<BR><FONT
class=Apple-style-span color=#000000><FONT class=Apple-style-span
color=#144fae><BR></FONT></FONT></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Speculators and hoarders are not the only forms of manipulation
and dysfunction that</DIV>
<DIV>tend to occur. Can you cite a single example of a long-term market that
was unregulated</DIV>
<DIV>and did not devolve as I describe? I believe that this is a statement of
fact over the</DIV>
<DIV>entire history of markets rather than merely my opinion.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">As far as 2, this danger seems to be manageable,
and there haven't been too many objections related to this lately. I
have argued that the stewards of the APNIC region, led by Geoff Huston,
considered this problem when deciding whether to have needs requirements
on transfers, and decided the benefits to >>Whois accuracy
outweighed the potential disaggregation problems. This cost is borne
most by network operators, who presumably can make decisions on minimum
block size which will allow them to run profitably. Those decisions will
likely shape the transfer market, so nobody expects there to be much
>>value in a /32 netblock, because network operators find this
size unprofitable to route today. This ability of network operators
provides a constraint on disaggregation in the transfer
market.<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite"><BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">People haven't been repeating what they already
said. That does not mean that it is not still a factor, merely that we
didn't<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">think we needed to repeat ourselves on a topic
already covered.<BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">In what way do you believe this danger would be
manageable and/or managed under the proposed
policy?<BR></BLOCKQUOTE><BR>Primarily, I associate my decision with Geoff
Huston's decision at APNIC.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>OK...</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>Geoff is one of the world's top experts on BGP, I think it fair to say,
and yet he viewed the danger to Whois accuracy in maintaining needs as
outweighing the danger of disaggregation.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Geoff's statements were actually more along the lines of what's
about to happen with BGP will happen whether we register it in whois or not
and</DIV>
<DIV>he did not believe that efforts at stewardship on the part of the RIRs
could prevent it, so, he thought it was better for the RIRs to attempt
to</DIV>
<DIV>accurately record the disaster than try to prevent it.</DIV>
<DIV><BR></DIV>
<DIV>I am not as fatalistic as Geoff and I think that in general, the ARIN
community is less fatalistic than the APNIC community. As such, I think
there</DIV>
<DIV>is value in attempting to prevent the disaster rather than merely
standing in front of the damn throwing my hands up in the air and writing
down</DIV>
<DIV>the precise time that it bursts before I am overwhelmed with water (which
is basically Geoff's approach).</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>Secondarily, I believe that private network operators are the ultimate
decisionmakers here. If they won't route a netblock, the value of the
netblock is reduced significantly.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Of course they are. I believe that private network operators
will see value in RIR stewardship of the resources</DIV>
<DIV>and will look to the RIRs for guidance on what should or shouldn't get
routed. If the RIRs make insane decisions,</DIV>
<DIV>the value of the RIR data for that purpose will be degraded. Allowing a
free-for-all in transfers would be an example</DIV>
<DIV>of an insane decision that would cause just such a degradation.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">Your belief that the ability of network operators
will place a constraint on disaggregation in the transfer
market<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">presumes a number of facts not in evidence. Namely
that:<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">+ There is some direct correlation between what
people will buy and what they can get routed.<BR></BLOCKQUOTE><BR>What kind
of evidence would satisfy you? The absence of recorded /32
transactions?<BR>Just use common sense, and put yourself in the position of
a buyer.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Buyers will believe that they can get /24s routed. However,
beyond a relatively small number of</DIV>
<DIV>additional /24s, this will prove to be impossible to sustain on the
internet.</DIV>
<DIV><BR></DIV>
<DIV>I'm not talking about the obvious case of /32s. I'm talking about the
fact that this market will force</DIV>
<DIV>a shortening of acceptable prefixes to prevent collapse. The speed at
which that shortening will</DIV>
<DIV>occur is likely to exceed the speed at which the buyers can adapt.</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">+ There is some correlation between what engineers
can profitably route and what sales people<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">will actually sell.<BR></BLOCKQUOTE><BR>There is a
correlation, because if the sales people continue to sell unprofitably, the
company will go out of business.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>But there can be a tremendous amount of disruption between
event A and event B in your statement</DIV>
<DIV>above. Also, if that were actually true, some ISPs that are in business
today would be long gone.</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">+ The feedback mechanism on these factors is fast
enough that the market can keep pace with<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">the effect the market is having on
them.<BR></BLOCKQUOTE><BR>To keep the market moving at its quickest pace,
lower transactional costs like the artificial needs
analysis.<BR>Surely having that requirement will slow transactional pace as
well as drive transactions off the books.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>It may slow the transactional pace, but, I don't believe that
is contrary to the goal here. The fast transaction</DIV>
<DIV>actually makes the problem I am describing worse, not better. If it is
slower, the buyer has some time</DIV>
<DIV>to realize that the routing situation has changed since he began the
transaction and adapt his</DIV>
<DIV>behavior. If the transaction closes quickly and the routing environment
changes between the time</DIV>
<DIV>that he made his purchase and the time he can get it routed, he may have
just purchased an</DIV>
<DIV>entirely worthless block of addresses with no recourse.</DIV>
<DIV><BR></DIV>
<DIV>As to driving transactions off the books, I think that the risks
associated with an off-the-books</DIV>
<DIV>transaction are higher than most organizations will find acceptable. I
think that ARIN can take</DIV>
<DIV>steps to make them riskier still (and probably should).</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">+ There actually is a feedback mechanism by which
the market and disaggregation will regulate<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">each other to some livable
equilibrium.<BR></BLOCKQUOTE><BR>The feedback mechanism is price. The
network operators will effectively set the floor for size.<BR>The price will
reflect the netblock's routability.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>You have not yet built the case that this feedback will
actually be effective at protecting the</DIV>
<DIV>buyer's interests. The operators may have to change the floor size faster
than the market</DIV>
<DIV>will change price, or, at the very least there will be some lag between
the two. What</DIV>
<DIV>happens to purchasers caught in that lag?</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">In order to believe that this is not an issue, I
think you would have to demonstrate that each of those<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">assertions has at least a reasonable chance of
being correct.<BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">And as far as 3, I have argued that speculators
provide a value to free markets, that most attempts to corner markets
fail, that supply uncertainty and IPv6 deployment provide a poor
environment for speculators. But inasmuch as this forum is populated by
technical types who are making decisions here based >>on their
understanding of, and philosophy of, economics, I have decided to take
David Farmer's advice and add an anti-speculator, anti-hoarder
protection in the form of a limit of a /12 equivalent for needs-free
transfers per 12 month period. If more transfers than that are desired,
the recipient will have to >>demonstrate
need.<BR></BLOCKQUOTE></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">Actually many attempts to corner markets in the
case of a truly finite market with players that have effectively
unlimited<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">resources _AND_ motivations other than direct
profit from the value of the market commodity
succeed.<BR></BLOCKQUOTE><BR>Could I get some examples from the many you
allude to?<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Tulips</DIV>
<DIV><BR></DIV>
<DIV>Enron (Natural Gas)</DIV>
<DIV><BR></DIV>
<DIV><A
href="http://blog.uncommonwisdomdaily.com/cornering-the-copper-market-5802">http://blog.uncommonwisdomdaily.com/cornering-the-copper-market-5802</A>
(current price of copper)</DIV>
<DIV><BR></DIV>
<DIV><A
href="http://www.indexmundi.com/commodities/?commodity=cocoa-beans">http://www.indexmundi.com/commodities/?commodity=cocoa-beans</A></DIV>
<DIV>The spike Jan-Mar 2011 appears to be the result of a 2010 market
cornering move by a British gentleman and his hedge fund.</DIV>
<DIV><BR></DIV>
<DIV>Worldcom (alternate fiber suppliers through much of the 1990s).</DIV>
<DIV><BR></DIV>
<DIV>I'm sure there are more.</DIV>
<DIV><BR></DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">While attempts to corner relatively large, and
especially dynamically elastic markets (such as finished goods) by
relatively small (value<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">of player as compared to overall value of market)
players are, in fact, doomed, that is not an accurate
description<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">of the likely IPv4 address
market.<BR></BLOCKQUOTE><BR>I have already pointed out the obvious risk that
CGN has for anybody who tries to corner the market.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>And I have trouble taking that seriously as LSN is just not a
technology that will suit the majority of providers</DIV>
<DIV>or consumers well at all.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>There is also the very obvious risk that IPv6 will finally take
off.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>This will happen regardless of the IPv4 market's behavior.
However, that does not prevent extreme short term</DIV>
<DIV>disruption by the IPv4 market.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>And when there is an alternative, the very action of the cornerers
drives the market to that alternative, posing additional risks to these
speculators.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Those alternatives will take time to be implemented and become
truly viable alternatives. IPv6, especially cannot be a unilateral
alternative</DIV>
<DIV>and requires implementation by at least three distinct groups to reach
viability. (consumers and their hardware, ISPs, and content providers).</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>As to the smallness of the market, we are in fact talking about a
trillion dollar network running on a pool of 3.8 billion address units worth
at least $40 billion right now.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>So? In units of 256 addresses, that's only less than 16.7
million salable unites in the entire market. (or did you forget that you can't
sell /32s?).</DIV>
<DIV><BR></DIV>
<DIV>Any market with a total of 16.7 million units defining the market is
pretty small by almost any definition.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>An international commodities market consisting of fungible, valuable,
and transportable assets is in the offing.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Hardly.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>The supply source of unknown depth and availabilty, although we know
the total upper bound of the market.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>The realistic upper bound is somewhere in the neighborhood of
about 12 /8s, probably quite a bit less.</DIV>
<DIV>That's a total market size of 786,432 /24s. Seems pretty small to
me.</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>And of course, no evidence of this activity that you can point to
in the nascent APNIC marketplace as evidenced by <A
href="http://tradeipv4.com">tradeipv4.com</A>.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>The APNIC marketplace hasn't started in earnest. Most providers
haven't even gotten their final /22 from APNIC yet.</DIV>
<DIV>Using that as an example at this time is absurd at best.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite"><BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">As a whole, then, my policy seeks to recognize
that there are transfer transactions which provide incentives for buyers
and sellers of addresses but which transactions may not meed the needs
requirements which ARIN mandates for
transfers.<BR></BLOCKQUOTE></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">There are thefts of automobiles which meet the
needs of car thieves and the resellers who purchase the
stolen<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">cars from them. That does not make the
legalization of car theft attractive.<BR></BLOCKQUOTE><BR>Geez, maybe you
should have used kidnappers of children and the child-sex rings who purchase
them!<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>An equally valid example.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>You obviously have an emotional view that transfers of addresses are
akin to theft from the rightful owner, ARIN.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Not at all. However, transfers of addresses absent justified
need are akin to theft from the community as a whole.</DIV>
<DIV>You can call that emotion if you want. I call it stewardship.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>In that I think you act more as king than steward.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>I suspect that is a reflection of your misunderstanding of my
viewpoint more than anything else.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>At least in terms of legacy space, the holders of address rights
*predate* ARIN, and yet in your mind, if they transfer them without telling
ARIN, they are thieves and hijackers.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>The holders of address registrations predate ARIN, but, ARIN is
the successor in interest to the original registries that</DIV>
<DIV>issued them. The resources are and were issued in trust in the community
interest to the original resource holder.</DIV>
<DIV>If a merger or acquisition results in the transfer of the underlying
network infrastructure and the addresses go with</DIV>
<DIV>it, that is a permitted transaction which should be recorded by the
current registry. Any other transaction transferring</DIV>
<DIV>addresses outside of policy is a theft of community resources and the
registry has the obligation to reclaim them in</DIV>
<DIV>the interests of the community.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">The question is whether removing the needs basis
benefits the ARIN community as a whole, not just the individual
participants in any particular<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">transaction. ARIN does not need to make policy
to the benefit of individual participants in a
transaction.<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">Our role as stewards is to make policy to the
benefit of the community as a whole. Individual participants in
a<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">transaction are quite capable of looking out for
their own immediate interests without involving ARIN
policy.<BR></BLOCKQUOTE></BLOCKQUOTE><BR>My rationale is the stewardship of
Whois, which benefits the entire Internet
community.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Except you have yet to establish any link whatsoever between
your policy and any positive effect on whois.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">Additionally, I pointed out that network
operators, in my experience, will route addresses whose Whois record
does not reflect that the network operator's customer is the registrant.
The network operator, in my experience, will normally check to make sure
that nobody else is advertising the addresses, and >>will solicit
from the customer some documentary evidence that the customer has the
right to the route the addresses, and then the network operator will
route the addresses.<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite"><BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">This is not my general experience. Most reputable
operators will refuse to route addresses unless they have<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">some reason to believe that the customer asking
them to route them has some legitimate registration of
those<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">resources.<BR></BLOCKQUOTE><BR>The legitimate reason
is the documentary evidence of transfer in the form of a merger,
acquisition, asset sale, or Letter of Agency.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>I suspect that if the LoA is found to conflict with the whois
database, it won't be worth the paper it is printed on. I suspect this</DIV>
<DIV>will become even more so in the coming years.</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">Sure, there are ISPs that specialize in routing
hijacked space to the benefit of snowshoe spammers<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">and the like, but, they are relatively rare and
tend to get de-peered over time.<BR></BLOCKQUOTE><BR>And how is a company
with a three-year planning window like a snowshoe spammer or
hijacker?<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Huh?</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>These companies cannot pass the ARIN needs requirements, and would be
incentivized to purchase enough addresses on the transfer
market.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>That's true today. However, to protect the community overall,
the community has come to agreement on a 1 year planning window for
addressing</DIV>
<DIV>purposes. This provides balance between those with need today and others
with need tomorrow.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>The seller is incentivized by the money the buyer will
pay.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Not seeing how this is relevant to the point.</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>The network operator is incentivized by the money the buyer will pay
him, and is satisfied by documentary evidence of the transfer that the buyer
has the right to route.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Again, I suspect that when it comes down to an issue of that
evidence vs. whois, most ISPs will likely go with whois and suggest</DIV>
<DIV>that the buyer go sort it out with ARIN and come back.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>The net result is Whois inaccuracy (and the fact that the buyer will
have no RSA with ARIN).<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>
<DIV>I suspect not as much as you think.</DIV>
<DIV><BR></DIV><BR>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">I agree that ARIN should get more aggressive about
removing registrations for addresses which are no longer<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">being held by the original resource holder or its
legitimate successor through some form of section 8
transfer.<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">ARIN should then reissue those available resources
to organizations with documented need in a timely
manner.<BR></BLOCKQUOTE><BR>This is your stick to my carrot. And wielding
that stick can get very expensive for ARIN through legal costs.<BR>And as
far as legacy addresses go, ARIN can spend through the nose on lawyers, but
my reading of MS/Nortel and the Plzack declaration in the Kremen case leads
me to believe that would be money ARIN would waste.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>I guess we'll see what happens. Worst case, the market blows
out the routing table and we all end up on IPv6</DIV>
<DIV>whether the IPv4 stuff is recorded in whois or not. Best case, the market
doesn't completely destabilize IPv4</DIV>
<DIV>before we get migrated to IPv6 and IPv4 becomes largely irrelevant. I
guess either way, this becomes a</DIV>
<DIV>relatively temporary problem. I suppose since I favor a faster migration
to IPv6, I should probably support</DIV>
<DIV>the greater disruption to IPv4 brought about by your policy, but, in the
interests of the community, I just</DIV>
<DIV>can't bring myself to do so.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">The net effect of these types of transactions is
a lack of trust in the Whois table as an accurate source to check for
authoritative routing rights. My proposal seeks to reduce the harm to
Whois accuracy by extending the range of allowable transactions,
providing additional incentive to have transfers reflected
>>accurately by ARIN's updating of Whois to reflect the
transfer.<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite"><BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">There is no evidence whatsoever that this newfound
range provides any incentive whatsoever for those<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">transactions to be
registered.<BR></BLOCKQUOTE><BR>Owen, you said a couple of paragraphs ago
that network operators would check registration when asked by a customer to
route addresses.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Yes... Regardless of the range allowed by policy, so long as it
remains reasonably sane.</DIV>
<DIV><BR></DIV>
<DIV>
<BLOCKQUOTE type="cite">
<DIV>I agree that is the first place they would go, and that is one of the
incentives for address transferees to seek
registration.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Exactly.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>The other is the fact that this is really the only public venue for the
registration of ownership rights, and I believe registration increases the
resale value of the addresses.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>They are not ownership rights. They are registrations.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>I point again to MS/Nortel and the luckiness that MS had a need exactly
equal to a previously negotiated sale with Nortel.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>You call it luck, I call it planning. Why would you purchase an
amount different than your need?</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>Had that need not matched precisely with the addresses allocated to
Nortel's acquisitions 20 years ago, what would have
happened?<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>The deal would have been modified.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>I think we all know what would have happened, and that is that
Microsoft would soon be routing those addresses, and Whois would still list
Nortel, or even some Nortel acquistion, as the
registrant.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>No, I don't think that would have happened.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>This was the spur for my proposal. Had the needs requirement not been
in place, the transaction could have flowed through 8.3, and the natural
incentives towards registration would have caused Whois to accurately
reflect Microsoft as the new registrant.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>The transaction is flowing through 8.3 and Micr0$0ft will
become the new registrant when it is complete.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>In addition to this public transaction, I offered some other potential
transactions which would also fail the needs test, among which is a buyer
with a 2 year planning horizon.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Yes, you've offered several instances in which behavior that
the community has said is contrary to the interests of the</DIV>
<DIV>community would be supported by your policy. That does not change the
fact that the behavior in question is contrary</DIV>
<DIV>to the stated interests and intents of the community.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>I will continue to use this example, as recent proposals to extend the
needs window attest to the belief among some that having a 2 year
planning window does not put you in the same league as spammers,
speculators, and hijackers.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>And I will point out that there is also opposition in the
community to those proposals indicating that there is belief among some</DIV>
<DIV>that having an ability to glom more than a year of address space at a
time to the exclusion of others is contrary to the interests</DIV>
<DIV>of the community.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>
<BLOCKQUOTE type="cite">Yes, it might actually remove some small amount of
disincentive, but, I believe<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">it would be better for ARIN to provide incentive
for accurate whois through a more active audit and<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">reclamation process as that would also better
serve the community by reducing the probability of hijacked<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">space being invisibly routed as well as making
some abandoned resources available to the ARIN community<BR></BLOCKQUOTE>
<BLOCKQUOTE type="cite">for reuse.<BR></BLOCKQUOTE><BR>Again with the stick.
How successfully as this stick been weilded in the
past?<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>It has not been wielded yet to my knowledge, so, there is not
yet a test on its success.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV><BR>
<BLOCKQUOTE type="cite">
<BLOCKQUOTE type="cite">As we move into a trading world, which will
happen whether or not my proposal passes, conflicts over address control
are likely to increase, and the value of trust in Whois as the routing
authority will also increase. Rather than sit back and watch Whois
decay, I urge ARIN stewards to consider making these >>changes to
foster accuracy in Whois.<BR></BLOCKQUOTE></BLOCKQUOTE>
<BLOCKQUOTE type="cite"><BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">There is no proof these changes will foster
accuracy in Whois.<BR></BLOCKQUOTE><BR>
<BLOCKQUOTE type="cite">Owen<BR></BLOCKQUOTE><BR>There is proof that
transfers have occurred that have not been reflected in Whois. John
mentioned the current 8.2 requests to reflect old mergers and
acquisitions.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Yes and I fully support ARIN recognizing appropriate transfers
before taking action to reclaim or revoke</DIV>
<DIV>resources by removing their registrations from the database and placing
the numbers back into the allocation</DIV>
<DIV>pool.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>So we know that transfers have occurred among the non-reprobate which
are not reflected in Whois.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>And? In most of those cases, they were unaware of ARIN and did
not know how to go about registering</DIV>
<DIV>their transfer. Upon rectification of that ignorance, most complete the
transfer without issue. I fail to see</DIV>
<DIV>how this provides any support for your proposal.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>I have pointed out that there is a major change afoot, the
development of an ip address transfer market.<BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV>Yes. I still haven't seen you provide any evidence that said
change means we should stop regulating the</DIV>
<DIV>rate of consumption in the interests of the community as a whole as part
of good stewardship.</DIV>
<DIV><BR>
<BLOCKQUOTE type="cite">
<DIV>So looking in the past for proof, or really looking anywhere for proof
of results of a change which has not occurred yet, is
specious.<BR><BR></DIV></BLOCKQUOTE>
<DIV><BR></DIV></DIV>At least some supporting evidence that your proposed
change would have the results you claim it
<DIV>would have would be useful. So far, there is none.</DIV>
<DIV><BR></DIV>
<DIV>Owen</DIV>
<DIV><BR></DIV></BLOCKQUOTE></BODY></HTML>