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<p>I don't think the problem is only the language but the main point
which it implicates in the whole ecosystem.<br>
</p>
<p>I agree with Owen's point that the solution to those who cannot
transfer is a combination of IPv6 and NRPM 4.10.<br>
In other RIRs there are, in my view, very successful and fair
policies for IPv4 exhaustion that only assigns a maximum of a /22
to newcomers and which would address this issue. Unfortunately
this has not been the same here.<br>
I also see the same way as Albert that in most cases leases will
be required for abusers and those seeking for long term may just
transfer which is available and works.<br>
</p>
<p>Regarding the analogy the car is a private property, while the IP
space by contract is not (Section 7 of the RSA)<br>
</p>
<p>Fernando Frediani<br>
</p>
<div class="moz-cite-prefix">On 01/11/2019 14:41, Scott Leibrand
wrote:<br>
</div>
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cite="mid:CAGkMwz708D_UR=jTNieaTd_43RH_nL9V71WpWfWCj+xPjujUjQ@mail.gmail.com">
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<div>In my opinion, it makes sense to allow leasing if we
require that addresses only be (re-)assigned to organizations
who'll be using them on an operational network. I think we're
looking for language something like:<br>
<br>
<b>ARIN allocates or assigns number resources to organizations
via transfer for the purpose of use on an operational
network. Organizations receiving number resources via
transfer may reallocate or reassign number resources to
organizations that do not receive connectivity from the
registrant for use on another operational network.<br>
</b></div>
<div><br>
</div>
<div>Further arguments inline below.</div>
<div dir="ltr"><br>
</div>
<div dir="ltr">On Fri, Nov 1, 2019 at 9:19 AM <<a
href="mailto:hostmaster@uneedus.com" moz-do-not-send="true">hostmaster@uneedus.com</a>>
wrote:<br>
</div>
<div class="gmail_quote">
<blockquote class="gmail_quote" style="margin:0px 0px 0px
0.8ex;border-left:1px solid
rgb(204,204,204);padding-left:1ex">I also agree with what
has been said, and am also opposed to the proposal.<br>
<br>
Some of the justification seems to be in the form of "I
cannot afford to <br>
buy a car, so I demand that someone permit me to lease
one". Noone is <br>
going to get into the car leasing business unless they can
make money. <br>
Generally the only money making segment is going to be the
short term, <br>
since the lessors profit is going to make buying cheaper
than leasing in <br>
the longer term. I think the same applies to IP leasing.<br>
<br>
In the case of IP address leasing, the only major users of
short term <br>
leases are abusers. The advancers of this proposal talk of
longer term <br>
leases to get discussion away from those abusers. However,
most of the <br>
time, someone wanting a long term lease would be better off
to buy, as <br>
they can always sell them on again at the end of the need
and often <br>
recover nearly all of their original investment, effectively
having a <br>
short term use of the address space nearly free.</blockquote>
<div><br>
</div>
<div>Nope, transferring purchased addresses and then
re-transferring them after < 12 months is disallowed by
current rules (with the goal of preventing speculation).</div>
<div><br>
</div>
<div>To extend your analogy, we currently disallow anyone from
selling a car they've owned for less than a year. Some
people would really like to rent a car for a shorter
duration, so they do so. But the DMV has rules requiring you
to make regular use of your current cars before you can buy
an additional one, and doesn't consider short-term rental to
be a legitimate use, so they won't issue license plates for
companies that rent out most of their cars and want to
obtain more cars to also rent out.</div>
<div><br>
</div>
<div>-Scott</div>
<div> </div>
<blockquote class="gmail_quote" style="margin:0px 0px 0px
0.8ex;border-left:1px solid
rgb(204,204,204);padding-left:1ex"> I think the long term <br>
IP leasing business model will not work.<br>
<br>
The only valid leasing I can see is an entity that has
excess address <br>
space that they expect to use in the future, and I think
that case is <br>
already addressed in the current rules. They would also be
unlikely to <br>
lease to someone that is an abuser, since they will have to
live with the <br>
block reputation after the lease ends.<br>
<br>
Albert Erdmann<br>
Network Administrator<br>
Paradise On Line Inc.<br>
<br>
On Fri, 1 Nov 2019, Fernando Frediani wrote:<br>
<br>
> <br>
> Exactly, and the main justification for this proposal
to allow subleasing is a total misuse of IP addressing and
a try to privilege specific companies in<br>
> detriment to all others.<br>
> <br>
> I do not agree that legitimizing leasing as such
increases accessibility to IPv4 space. Organization already
have access to it by transfers. By allowing<br>
> leasing as such prices of both leasing and transfer has
the potential to rise significantly as organizations will
prefer much more to sublease than to<br>
> transfer which is logic to think that will increase
pricing in general for both and which is only interesting to
those who are involved in the transaction<br>
> and not to those who are seeking for IPv4 space and
have already access via transfers.<br>
> The point about keeping the correct registry updated is
not a justification either because this is already a
obligation. If someone is not doing that or is<br>
> doing things in a different way is going against the
current policies. Any organization who signed a contract
when they became a member accepted to follow<br>
> these rules and they must bound to them, not the other
way round.<br>
> As said there is not reasons to issue addresses to
anyone who will not be using them on a operational network
other than legitimate speculation of IP space.<br>
> <br>
> I consider the current text in NRPM as appropriate and
therefore I oppose this proposal in full.<br>
> <br>
> Regards<br>
> Fernando<br>
> <br>
> On 01/11/2019 11:28, Owen DeLong wrote:<br>
> I have trouble with both phrases.<br>
> Even if the resources are to be re-assigned to
organizations or entities which do not receive connectivity
from the original registrant, I see no<br>
> reason to issue addresses to anyone who will not be
using them on an operational network.<br>
> <br>
> Owen<br>
> <br>
><br>
> On Oct 31, 2019, at 3:10 PM, Scott Leibrand <<a
href="mailto:scottleibrand@gmail.com" target="_blank"
moz-do-not-send="true">scottleibrand@gmail.com</a>>
wrote:<br>
> <br>
> On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil
<<a href="mailto:k@openiadvisors.com" target="_blank"
moz-do-not-send="true">k@openiadvisors.com</a>> wrote:<br>
> Dear All,<br>
> Prior to tomorrow's community discussion of Draft
Policy ARIN-2019-18, I wanted to offer some clarification
and propose some language for<br>
> consideration to address questions posed on the PPML.<br>
> <br>
> Regarding the question over the intended meaning of
"non-connected networks", I will clarify that I mean this
policy to refer to<br>
> re-assignment to organizations and entities which do
not receive connectivity from the original registrant. <br>
> <br>
> As such, I wanted to offer the following alternative
edit to 8.5.2: <br>
><br>
> 8.5.2 Operational Use<br>
> <br>
> ARIN allocates or assigns number resources to
organizations via transfer primarily for the purpose of use
on an operational network,<br>
> but may allocate or assign number resources to
organizations for other purposes, including re-assignment to
organizations and<br>
> entities which do not receive connectivity from the
original registrant.<br>
> <br>
> <br>
> I believe this is consistent with the intent of
2019-18, and I would support this language.<br>
> <br>
> <br>
> <br>
> Alternatively, and more simply, since the sentence
referencing "non-connected networks" starts with "including"
and is therefore not meant<br>
> to be an exclusive "other purpose", but rather
illustrative, we can remove it entirely. That option would
read: <br>
><br>
> 8.5.2 Operational Use<br>
> <br>
> ARIN allocates or assigns number resources to
organizations via transfer primarily for the purpose of use
on an operational network,<br>
> but may allocate or assign number resources to
organizations for other purposes. <br>
> <br>
> I believe this is materially different than the text
above, in that it would give ARIN permission to approve
transfers for any reason<br>
> whatsoever. ARIN in the past has interpreted such
ambiguity in favor of allowing whatever is not expressly
prohibited. As such, I don't think<br>
> this language accomplishes the original intent, and
would oppose it.<br>
> <br>
> -Scott<br>
> <br>
><br>
> *please note that the online version of the
policy proposal reads "solely primarily" instead of
"primarily". This is a<br>
> typo due to originally proposing the
language with the word "solely" in strike-through text
(solely), which did not<br>
> translate. <br>
> <br>
> Further, I want to clarify, as the original author of
the proposal, that the key intent of the policy is to
acknowledge that small and<br>
> medium-sized businesses have a need for IPv4 space, but
often cannot afford to buy space in the current market.
Legitimizing a subleasing<br>
> market increases accessibility to IPv4 space, and opens
the market to business solutions to facilitate safe, trusted
subleasing practices,<br>
> including keeping the correct registry updated. <br>
> Thanks all for the continued discussion. <br>
> <br>
> Best,<br>
> <br>
> Kiran<br>
> --<br>
> Kiran Malancharuvil<br>
> Open-i Advisors <br>
> p: 415 419 9138<br>
> <a href="http://openiadvisors.com" rel="noreferrer"
target="_blank" moz-do-not-send="true">http://openiadvisors.com</a><br>
<br>
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