<html><body><div style="font-family: arial, helvetica, sans-serif; font-size: 12pt; color: #000000"><div>Originally <br>12 years ago when I tried to get ARIN resources, I was greatly harmed by this.<br>In Missouri at that time a Sole Proprietor did not have to register with the Secretary of State.<br>ARIN would not issue resources unless they could verify you with Secretary of State database.<br>We had a State Sales Tax and Employment Tax ID for 20 years, but that wasn't good enough.<br>3-4 years later the Secretary of State would allow us to request a fictitious name which couldn't match our legal name and individual.<br>That still wasn't good enough for ARIN.<br>2 years later we setup an LLC and got an ASN number to move between upstream bandwidth suppliers but IPv4 was now gone.<br>Our upstream supplier clawed back a /22 and /23 which caused great harm because we couldn't replace them.<br>So yes ARIN CAUSED GREAT HARM in not accepting our state resale number as proof of business as a sole proprietor.</div><div>Secretary of State still doesn't require registration in Missouri if you have a state Tax ID through Department of Revenue.<br>And now in our LLC which ARIN would use. An LLC of 1 member, the Missouri Department of Revenue says must have at a minimum of 2 members<br>even though the Secretary of State says an LLC of 1 is OK.<br>So about 5 years of great harm.<br><br></div><div><br></div><hr id="zwchr" data-marker="__DIVIDER__"><div data-marker="__HEADERS__"><b>From: </b>"Andrew Dul via ARIN-PPML" <arin-ppml@arin.net><br><b>To: </b>"arin-ppml" <arin-ppml@arin.net><br><b>Sent: </b>Wednesday, April 16, 2025 3:55:48 PM<br><b>Subject: </b>Re: [arin-ppml] distributing resources for individuals<br></div><div><br></div><div data-marker="__QUOTED_TEXT__"><div class="moz-cite-prefix">Preston,</div>
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<div class="moz-cite-prefix">Do you have suggestion about what
barrier that needs to be removed? </div>
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<div class="moz-cite-prefix">While filing for a DBA or registering
as a business is a step, to me it seems like a very small step and
in many cases a much smaller step than applying to ARIN for number
resources. For example, in the state of Washington, one can file
online for about $55 and the process would probably take less than
10 minutes.</div>
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<div class="moz-cite-prefix">Andrew</div>
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<div class="moz-cite-prefix">On 4/16/2025 1:09 PM, Preston Ursini
via ARIN-PPML wrote:<br>
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Remove the barrier for legitimate networks operated by
individuals, the door shouldn’t be open for anyone, it needs to
remain in place for legitimate network operators that can justify
the needs for the assets, whether they be for an individual or
corporation.
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<div>The other requirements for numbering assets should otherwise
remain the same in relation to this proposed policy change, and
validated proof of identification of the individual should also
be recorded in some way.</div>
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<div>Looking further back at the issue, it is likely easier for
people committing fraud to incorporate fake companies through
state level secretary of state offices and work under the name
of a fake company versus working under the name of a fake
individual. So validating the identity of an individual,
whether the application be for a company or individual, is
probably a good idea all around. Name / Date of Birth /
Government Issued Identify Document at a minimum.
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<div>Preston Ursini<br id="lineBreakAtBeginningOfMessage">
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<div>On Apr 16, 2025, at 3:02 PM, John Curran
<a href="mailto:jcurran@arin.net" target="_blank" rel="nofollow noopener noreferrer"><jcurran@arin.net></a> wrote:</div>
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<div>Preston - <br>
<br>
As a point of clarity – when you suggest that
“removing this barrier should be given great
consideration”, do you mean for removing the barrier
for "legitimate networks operated by individuals”
(such as you referenced in your explanation), or for
removal of the barrier for individuals in general?<br>
<br>
Thanks,<br>
/John<br>
<br>
John Curran<br>
President and CEO<br>
American Registry for Internet Numbers<br>
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<blockquote>On Apr 16, 2025, at 3:51 PM,
Preston Ursini via ARIN-PPML
<a href="mailto:arin-ppml@arin.net" target="_blank" rel="nofollow noopener noreferrer"><arin-ppml@arin.net></a> wrote:<br>
<br>
I know of at least one individual that was working
to start a network and was harmed by this. He is a
colocation customer, unincorporated, and uses his
network for himself and his place of employment;
however the employer did not want to go through the
process of obtaining numbering assets from ARIN, and
the network is used for his own joint venture. He
simply saw the requirement and did not proceed.<br>
<br>
I would ascertain that most legitimate networks
operated by individuals is probably relatively
small, however our colo somewhat acts as a network
incubator giving a place for small networks to grow.
I believe most individuals stopped by this
requirement would not reach out to ARIN for change.
If you look at some IXPs you’ll see there are
plenty ran under assumed names, with some IXPs
themselves being ran by individuals that aren’t
incorporated.<br>
<br>
If you look into small ISPs and IXPs, and their
start, you’ll find that many of them start off as
unincorporated sole proprietors. One thing we’ve
found is that these networks are likely to end up
leasing IP space from an upstream provider as the
barrier to obtaining their own IP Assets may be seen
as too high. In short, this causes providers that
could probably get away with IPv6 + NRPM 4.10 IPv4
w/ CG-NAT are being forced to lease IPv4 as these
lessors have a financial incentive to show leased
IPv4 as a necessity for a new network, thus also
possibly having the effect of stalling IPv6 adoption
for these small networks that in turn grow into
large ones. Getting them onboarded w/ ARIN and
running IPv6 from the start would be a win. More
educational material for IPv6 and numbering planning
from ARIN would be great, and lowering and/or
removing perceived barriers to entry will do a lot
long term to help with this.<br>
<br>
In short: We help small networks navigate this, and
we have seen the requirement for a business license
/ assumed name / etc act as a barrier to entry for
small networks, and I believe even for small IXPs,
and may have a side effect of causing a barrier to
IPv6 adoption for small networks.<br>
<br>
I believe the notion of removing this barrier should
be given great consideration.<br>
<br>
Preston Ursini<br>
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