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<DIV>Hi Jason and thanks for your interesting reply.</DIV>
<DIV>As you know, my original proposal was not based on a cap that is based on
the size of the entity, but instead on the number of addresses allowed to be
transferred without a needs test per annum.There was a suggestion that this cap
instead be placed on the aggregate number of addresses held by an
organization.</DIV>
<DIV>The reason given was that these organizations would likely have more
experience with justifications, and that the needs test would be less of a
burden for them.</DIV>
<DIV> </DIV>
<DIV>I agree that this aggregate cap does burden the larger organizations, but
consider that these larger organizations by definition have fed at the trough of
the free pool extensively compared to their less endowed competitors. One could
argue that they are reaping the advantage of being there early and thus should
shoulder the burden of needs testing additional transfers that late entrants who
have to pay for their addresses should be exempted from. </DIV>
<DIV> </DIV>
<DIV>As for me, I think either version of the cap will serve to prevent hoarding
and market cornering, but will reply inline to some of your other
comments:</DIV>
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<DIV>
<DIV>>Consider a small rural residential ISP, with a /22.</DIV>
<DIV>>- This ISP is using a single /24 for loopback, point-to-point, </DIV>
<DIV>management network, and corporate network.</DIV>
<DIV> </DIV>
<DIV>>- This IPS has 615 customers each with a single IPv4 address.</DIV>
<DIV> </DIV>
<DIV>>- This ISP has seen fairly linear growth of 600 customers every two
years.</DIV>
<DIV> </DIV>
<DIV>>In 6 months they will exhaust their currently held space.</DIV>
<DIV>>They already qualify for another /22.</DIV>
<DIV>>Once they get this additional /22 that gives them addresses to cover 4
years.</DIV>
<DIV>>(/22 is about 3.4 years of customer + 6 months current available)</DIV>
<DIV> </DIV>
<DIV>>A /12 represents 6,990 years worth of address space</DIV>
<DIV>>A /16 represents 218 years of address space</DIV>
<DIV>>A /20 represents 13.5 years of address space</DIV>
<DIV> </DIV>
<DIV>>Should small organizations be able to by a virtually unlimited amount
of </DIV>
<DIV>address if they can afford it?</DIV>
<DIV> </DIV>
<DIV>First of all, it would be an odd rural residential ISP who could fork over
$10 million for a /12.</DIV>
<DIV>And a /12 is not the same as “virtually unlimited”, surely you know that.
The limit is just .0002 of available IPv4 space.</DIV>
<DIV> </DIV>
<DIV>>Should a large organization (who can demonstrate need) only be
permitted</DIV>
<DIV>to buy two years worth of address space?</DIV>
<DIV> </DIV>
<DIV>As I said, I am agnostic about whether the cap is on aggregate holdings or
annual transfers. But I would point out that it is the large companies who pose
the greatest risk of hoarding addresses, simply because they usually have the
required funds to risk in this endeavor. </DIV>
<DIV> </DIV>
<DIV>>Organizations have also realized they only have to do native IPv4 for
shortly longer </DIV>
<DIV>than their competitors then they can force all new customers into some sort
of </DIV>
<DIV>provider based large scale NAT (CGN 444 + IPv6 / GCN 644).</DIV>
<DIV> </DIV>
<DIV>>So now people are bracing for a slow and painful transition to
IPv6.</DIV>
<DIV> </DIV>
<DIV>>Never mind anti-competitive behavior of cornoring the market on IPv4
addresses,</DIV>
<DIV>think about reasonable players the feel the need to stockpile enough
addresses</DIV>
<DIV>to continue doing native IPv4 longer than their competition in order to not
loose </DIV>
<DIV>their customer base to competitors who can offer a better native IPv4
product when</DIV>
<DIV>you can't.</DIV>
<DIV> </DIV>
<DIV>>Which means getting years worth of IPv4 space...</DIV>
<DIV>>Which means we are not going to run out...</DIV>
<DIV>>Which means we can continue to save by deferring the cost</DIV>
<DIV>of deploying IPv6...</DIV>
<DIV>>Which menas buying more space...</DIV>
<DIV>>(if we are not ready to deploy IPv6 buy two more years
worth)</DIV>
<DIV>>(or if the industry hasn't embraced IPv6 in a real way buy enough to
last until it has)</DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV>I agree with what you are saying, although “forcing” customers into CGN is
not something I am aware of, rather this is being provided as an option to
users, with the ability to opt out, at least with the British deployments and
Verizon residential DSL. My Sprint 4G has been using CGN on squat space
for years without my ability to opt out, though. But if you take this view, that
an IPv4 market will provide a disincentive toward IPv6 deployment, maybe what
you should be after is policy designed to make the market less viable, less
vibrant, through increasingly onerous restrictions on transfers and allocations.
Also, if ISPs can realize a 10:1 or even 100:1 address savings ratio through the
use of CGN, wouldn’t they be more likely simply to introduce CGN and then hoard
the addresses they have saved, rather than go to the transfer market to buy
more? Note that this is only an option for those who already have large holdings
of IPv4 space.</DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV>>If you are looking to make needs justification easier then maybe
something like:</DIV>
<DIV>>- any org can transfer a single /22 no need required</DIV>
<DIV>>- any org can transfer up to four times the amount of address rounded
to </DIV>
<DIV>nearest CIDR utilized in the last year</DIV>
<DIV>> * (jan 1, had 14 M addresses in use, dec 31 had 17M)
3M = /20 qualify for /18</DIV>
<DIV>>- any org who transfered a /22 can get an additional /22 when the
current one is 80% </DIV>
<DIV>utilized even if they have utilized less than a 513 addresses in the last
year</DIV>
<DIV>> *( jan 1 had 711 addresses, dec 31 had 820) 109 = /25 </DIV>
<DIV> </DIV>
<DIV>>But agin the community will have to accept a four year window, which
will likely do </DIV>
<DIV>bad things to IPv6 deployment. If you made the threshold a /23, then
you could keep </DIV>
<DIV>the two year window... but they why not just go to RIPE or APNIC and get a
/22 from</DIV>
<DIV>the soft landing policy?</DIV>
<DIV> </DIV>
<DIV>I am heartened that you would even consider a /22 cap for needs free
transfers. </DIV>
<DIV>But I don’t think that this conversation should in any way preclude
consideration of some kind of soft-landing policy for free pool addresses.</DIV>
<DIV> </DIV>
<DIV>Regards,</DIV>
<DIV>Mike</DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV>Or we could let the businesses themselves decide how much they want to
spend to insure themselves against a potential long-term future for IPv4. Some
conservative entities may choose to buy “up to the cap” in this situation,
others who think IPv6 is close, or a new transition technology is in the offing,
might seek to sell addresses while they have value. It is in the interplay of
those transactions that a price will be derived, representing the opinions of
all transactors. </DIV>
<DIV>I think that what you are arguing is that a large number of buyers will
have the money and inclination to buy “up to the cap”, resulting in more overall
hoarding than if we maintained the needs test for all transfers. I think
this would require a kind of conspiracy or at least groupthink which I do not
perceive among buyers and sellers in the market.</DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV></DIV></DIV>
<DIV class=gmail_extra><BR><BR>
<DIV class=gmail_quote>On Thu, Jun 13, 2013 at 10:17 AM, Mike Burns <SPAN
dir=ltr><<A href="mailto:mike@nationwideinc.com"
target=_blank>mike@nationwideinc.com</A>></SPAN> wrote:<BR>
<BLOCKQUOTE
style="BORDER-LEFT: #ccc 1px solid; MARGIN: 0px 0px 0px 0.8ex; PADDING-LEFT: 1ex"
class=gmail_quote>
<DIV dir=ltr>
<DIV dir=ltr>
<DIV style="FONT-FAMILY: 'Calibri'; FONT-SIZE: 12pt">
<DIV>Hi Brian,</DIV>
<DIV> </DIV>
<DIV>Thanks for your thoughts. </DIV>
<DIV>No doubt a more vigorous transfer market will lead to more router
misconfigurations.</DIV>
<DIV>I think a knowledgeable middle-man could help mitigate that, and would
take business from the guy getting into the game without networking knowledge
you mention below.</DIV>
<DIV> </DIV>
<DIV>There is real uncertainty when dealing with the registries. A recent
transaction took nearly a month to complete, most of which was spent in the
back and forth of a justification. It’s always a fingers-crossed situation for
buyer and seller. One broker told me she does the “happy dance” every time a
deal makes it through justification.</DIV>
<DIV> </DIV>
<DIV>Your point about moving to IPv6 is important, because that move is the
800lb gorilla in the room.</DIV>
<DIV>Nobody knows when the move will happen or how long it will take,
but when it happens it is bound to affect IPv4 prices negatively.</DIV>
<DIV>Who would speculate under these conditions? </DIV>
<DIV>What if we limited his total purchases to a /12, or his aggregate
holdings to a /12, otherwise he would be needs-tested?</DIV>
<DIV> </DIV>
<DIV>Regards,</DIV>
<DIV>Mike</DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV> </DIV>
<DIV
style="FONT-STYLE: normal; DISPLAY: inline; FONT-FAMILY: 'Calibri'; FONT-SIZE: small; FONT-WEIGHT: normal; TEXT-DECORATION: none">
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<DIV><FONT size=3 face=Calibri></FONT> </DIV>
<DIV style="BACKGROUND: #f5f5f5">
<DIV><B>From:</B> <A title=bjones@vt.edu href="mailto:bjones@vt.edu"
target=_blank>Brian Jones</A> </DIV>
<DIV><B>Sent:</B> Thursday, June 13, 2013 9:30 AM</DIV>
<DIV><B>To:</B> <A title=mike@nationwideinc.com
href="mailto:mike@nationwideinc.com" target=_blank>Mike Burns</A> </DIV>
<DIV><B>Cc:</B> <A title=mike@iptrading.com href="mailto:mike@iptrading.com"
target=_blank>Mike Burns</A> ; <A title=arin-ppml@arin.net
href="mailto:arin-ppml@arin.net" target=_blank>arin-ppml@arin.net</A> </DIV>
<DIV>
<DIV class=h5>
<DIV><B>Subject:</B> Re: [arin-ppml] A Redefinition of IPv4 Need post
ARINrun-out(was:Re:Against2013-4)</DIV></DIV></DIV></DIV></DIV>
<DIV> </DIV></DIV>
<DIV>
<DIV class=h5>
<DIV
style="FONT-STYLE: normal; DISPLAY: inline; FONT-FAMILY: 'Calibri'; FONT-SIZE: small; FONT-WEIGHT: normal; TEXT-DECORATION: none">Mike,<BR
clear=all>See inline comments.<BR><BR>
<DIV class=gmail_quote>On Wed, Jun 12, 2013 at 10:05 PM, Mike Burns <SPAN
dir=ltr><<A href="mailto:mike@nationwideinc.com"
target=_blank>mike@nationwideinc.com</A>></SPAN> wrote:<BR>
<BLOCKQUOTE
style="BORDER-LEFT: #ccc 1px solid; MARGIN: 0px 0px 0px 0.8ex; PADDING-LEFT: 1ex"
class=gmail_quote><U></U>
<DIV bgcolor="#ffffff">
<DIV><FONT face=Arial>Hi Brian,</FONT></DIV>
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT face=Arial>I understand that there is a danger of overpurchasing
(by whomever's definition) that comes from the removal of a needs test for
transfers.</FONT></DIV>
<DIV><FONT face=Arial>In most cases we rely on the price of the addresses to
provide some check on this practice, as it would for the overpurchasing of
any other asset a corporation may choose to invest in. </FONT><FONT
face=Arial>I think we should leave those definition of what an overpurchase
is to the buyers, who will have a range of intended purposes, projected
growth rates, planning horizons and other considerations. At least with a
cap of some sort we limit the overpurchase risk to overall address usage
efficiency.</FONT></DIV>
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT face=Arial>A vibrant market is one of the best mechanisms to
prevent what you mention-the problem of addresses sitting idle while real
need exists.</FONT></DIV></DIV></BLOCKQUOTE>
<DIV><BR><BR>At the risk of contradicting myself, I'm not sure a vibrant
market is the <I>best </I>answer for the networking community, but I don't
disagree that what you propose would invigorate the market. See my comments
below about network stability.<BR><BR> </DIV>
<BLOCKQUOTE
style="BORDER-LEFT: #ccc 1px solid; MARGIN: 0px 0px 0px 0.8ex; PADDING-LEFT: 1ex"
class=gmail_quote>
<DIV bgcolor="#ffffff">
<DIV><FONT face=Arial>As the price of addresses rise and transactional
roadblocks diminish, idle addresses will come into the market. As the need
rises, the price will rise, driving efficiencies in the utilization of
addresses and wringing the most efficiency through the highest and best use
of the addresses.</FONT></DIV></DIV></BLOCKQUOTE>
<DIV><BR>I would agree that as demand rises the prices will increase, but
maybe, just maybe most folks will be considering the move to IPv6 where these
contentions and price increases will not exist.<BR> </DIV>
<BLOCKQUOTE
style="BORDER-LEFT: #ccc 1px solid; MARGIN: 0px 0px 0px 0.8ex; PADDING-LEFT: 1ex"
class=gmail_quote>
<DIV bgcolor="#ffffff">
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT face=Arial></FONT><FONT face=Arial></FONT><FONT face=Arial>And as
I mentioned, due to the needs test requirement, these early IPv4 address
transactions almost always involve neophyte parties on either side of the
transaction, separated by language, culture, and an ocean. Often these
parties are not familiar with their own RIR policy, much less the policy of
another region. Most of the time the decision to sell or buy addresses has
to overcome corporate inertia and antipathy to new, unusual, and
unlikely-to-be-repeated transactions. This means education about the RIRs
and their position squarely in the middle of the buyer and the
seller.</FONT></DIV>
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT face=Arial>How likely is this transaction to occur for small
allocations like the /24 needed by Mr. Ryerse of this thread?</FONT></DIV>
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT face=Arial>I contend that removing the needs requirement will
allow for less uncertainty in what is currently a fraught process for both
buyers and sellers, leading to more transactions, more price stability, and
simpler transactions for all parties, including ARIN, who will avoid the
time and effort of needs testing transfers.</FONT></DIV>
<DIV><FONT face=Arial></FONT> </DIV></DIV></BLOCKQUOTE>
<DIV><BR>I appreciate your contention, and it is possible that some of the
things you mention may actually pan out, but I do not agree with the "less
uncertainty" part of your statement. I would contend removing all needs
assessment would create more uncertainty by promoting that anyone can get in
the game of brokering IP addresses regardless of their knowledge about
networking. Also by increasing the amount of times IP addresses get swapped
around the Internet could increase the possibility for networking instability
and router misconfiguration issues. <BR><BR>--<BR>Brian<BR><BR> </DIV>
<BLOCKQUOTE
style="BORDER-LEFT: #ccc 1px solid; MARGIN: 0px 0px 0px 0.8ex; PADDING-LEFT: 1ex"
class=gmail_quote>
<DIV bgcolor="#ffffff">
<DIV><FONT face=Arial>Regards,</FONT></DIV>
<DIV><FONT face=Arial>Mike</FONT></DIV>
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT face=Arial></FONT> </DIV>
<DIV><FONT 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>
<DIV style="FONT: 10pt arial">----- Original Message ----- </DIV>
<DIV style="FONT: 10pt arial; BACKGROUND: #e4e4e4"><B>From:</B> <A
title=bjones@vt.edu href="mailto:bjones@vt.edu" target=_blank>Brian
Jones</A> </DIV>
<DIV style="FONT: 10pt arial"><B>To:</B> <A title=mike@iptrading.com
href="mailto:mike@iptrading.com" target=_blank>Mike Burns</A> </DIV></DIV>
<DIV>
<DIV>
<DIV style="FONT: 10pt arial"><B>Cc:</B> <A title=arin-ppml@arin.net
href="mailto:arin-ppml@arin.net" target=_blank>arin-ppml@arin.net</A> ; <A
title=mike@nationwideinc.com href="mailto:mike@nationwideinc.com"
target=_blank>Mike Burns</A> </DIV>
<DIV style="FONT: 10pt arial"><B>Sent:</B> Wednesday, June 12, 2013 9:28
PM</DIV>
<DIV style="FONT: 10pt arial"><B>Subject:</B> Re: [arin-ppml] A
Redefinition of IPv4 Need post ARINrun-out(was:Re:Against 2013-4)</DIV>
<DIV> </DIV>
<P>Hi Mike, </P>
<P>I suppose it is just my old school thinking that you should be at least
"this tall" to ride the ride. Given your explanations below I could relax
my requirements for demonstrating technical support need for transfers. I
actually didn't realize we were only considering transfers and not the
remaining free blocks, so thank you for clarifying that. </P>
<P>It still seems that inefficient use of address space could occur when a
bidder buys much larger blocks than needed due to the lack of any
structured needs requirements. At a minimum a block of addresses could sit
idle and unused while needs exists elsewhere. But really IPv6 should be
the best solution for those needing addresses moving forward any way... :)
</P>
<P>Brian <BR></P>
<P>On Jun 12, 2013 3:15 PM, "Mike Burns" <<A
href="mailto:mike@iptrading.com" target=_blank>mike@iptrading.com</A>>
wrote:<BR>><BR>> Hi Brian,<BR>> <BR>> Thanks for your
input.<BR>> <BR>> May I ask why you think there should be a
requirement for demonstration of minimal technical need for transfers, if
the reason is not to prevent hoarding and price
manipulation?<BR>> <BR>> Remember we are talking only about
transfers, and not the intelligent allocation of the remaining IPv4 free
pool, and that money will be the determining factor in who receives IPv4
addresses under the current transfer policy, so long as the needs test is
met. That is, we are already at a point where the highest bidder will get
the addresses, irrespective of what his justified need for the addresses
is, just that he has met the RIR need test.<BR>> <BR>> I have
been operating under the assumption that the underlying reason for
requiring the needs test for transfers which are already priced is to
prevent a buyer without needs from damaging the market through hoarding or
cornering. I understand that many people simply do not like the idea that
address blocks can be bought and sold, and that money has any influence on
who gets addresses, but we are beyond that now.<BR>> <BR>>
Regards,<BR>> Mike<BR>> <BR>> <BR>> From: Brian
Jones<BR>> Sent: Wednesday, June 12, 2013 2:54 PM<BR>> To: Mike
Burns<BR>> Cc: <A href="mailto:arin-ppml@arin.net"
target=_blank>arin-ppml@arin.net</A><BR>> Subject: Re: [arin-ppml] A
Redefinition of IPv4 Need post ARIN run-out(was:Re:Against
2013-4)<BR>> <BR>><BR>> Maybe that was utopian thinking on
my part. It would be nice to disregard what happens with IPv4 space but
that seems to invite some sort of chaos and the last thing needed is more
chaos...<BR>><BR>> Intelligent allocation of the remaining IPv4
space is important in my opinion.<BR>><BR>> From Dave Farmer's email
earlier:<BR>> "I think the more important issue is an appropriate
criteria on the lower-end and for new enterants, the current slow-start
for IPv4 isn't going to work, post-ARIN free pool. Yes, I know
eliminating need alltogether eliminates that problem, but I'm not sure I
can get myself all the way there. I'd like to see some minimal
technical criteria that entitles someone to be able to buy up to between a
/16 and a /12 and more than just that they have the money to do so.
Maybe its just as simple as demonstrating efficient use of at least a
/24. If you can't do that then you can only buy a /24, then you
utilize it and you qualify for bigger blocks. "<BR>><BR>> Regardless
of whether the size blocks discussed is agreeable or not, I do agree wth
the part about the need for "...minimal technical criteria that entitles
someone to be able to buy up to between a /16 and a /12 and more than just
that they have the money to do so."<BR>><BR>> (Of course I support
the idea that we all move to IPv6!) :)<BR>><BR>> --<BR>>
Brian<BR>><BR>><BR>> On Wed, Jun 12, 2013 at 11:20 AM, Mike Burns
<<A href="mailto:mike@nationwideinc.com"
target=_blank>mike@nationwideinc.com</A>>
wrote:<BR>>><BR>>> Hi Brian, Matthew, and
Martin,<BR>>> <BR>>> Can I take your plus ones to
indicate support of the cap even in the face of the shell company
issue?<BR>>> (As well as support of the idea that we should all move
to IPv6.)<BR>>> <BR>>> Regards,<BR>>>
Mike<BR>>> <BR>>> <BR>>> From: Brian
Jones<BR>>> Sent: Wednesday, June 12, 2013 11:03 AM<BR>>> To:
<A href="mailto:arin-ppml@arin.net"
target=_blank>arin-ppml@arin.net</A><BR>>> Subject: Re: [arin-ppml]
A Redefinition of IPv4 Need post ARIN run-out (was:Re:Against
2013-4)<BR>>> <BR>>> <BR>>>
<BR>>> <BR>>> <BR>>> On Tue, Jun 11, 2013 at
10:42 PM, Martin Hannigan <<A href="mailto:hannigan@gmail.com"
target=_blank>hannigan@gmail.com</A>>
wrote:<BR>>>><BR>>>> On Tue, Jun 11, 2013 at 10:24 PM,
cb.list6 <<A href="mailto:cb.list6@gmail.com"
target=_blank>cb.list6@gmail.com</A>>
wrote:<BR>>>>><BR>>>>><BR>>>>> On Jun
11, 2013 7:15 PM, "Matthew Kaufman" <<A
href="mailto:matthew@matthew.at" target=_blank>matthew@matthew.at</A>>
wrote:<BR>>>>> ><BR>>>>> > When will we
start caring about IPv6 and start ignoring IPv4??? Who cares if people set
up shells to acquire v4 space from others? Let 'em, and get v6 deployed
already.<BR>>>>> ><BR>>>>><BR>>>>>
+1<BR>>>>><BR>>>>>
CB<BR>>>><BR>>>><BR>>>>
+1<BR>>>><BR>>>> Best,<BR>>>><BR>>>>
-M<BR>>>><BR>>>><BR>>><BR>>><BR>>>
+1<BR>>><BR>>> --<BR>>>
Brian<BR>>><BR>>>
<BR>>>><BR>>>><BR>>>>
_______________________________________________<BR>>>>
PPML<BR>>>> You are receiving this message because you are
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href="mailto:ARIN-PPML@arin.net"
target=_blank>ARIN-PPML@arin.net</A>).<BR>>>> Unsubscribe or
manage your mailing list subscription at:<BR>>>> <A
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Please contact <A href="mailto:info@arin.net"
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________________________________<BR>>>
_______________________________________________<BR>>>
PPML<BR>>> You are receiving this message because you are subscribed
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Please contact <A href="mailto:info@arin.net"
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<DIV><SPAN style="FONT-FAMILY: arial; COLOR: rgb(0,0,0)"><FONT color=#555555
face="'courier new', monospace">_______________________________________________________<BR></FONT>
<DIV><FONT face="'courier new', monospace">Jason Schiller|NetOps|<A
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target=_blank>jschiller@google.com</A>|571-266-0006</FONT></DIV>
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