US CODE: Title 15, Chapter 1, Section 2.

Michael Dillon michael at MEMRA.COM
Fri Jan 31 18:37:24 EST 1997


On Fri, 31 Jan 1997, Karl Auerbach wrote:

> > Well, you are simply wrong about this. ARIN is not the sole source. If any
> > organization is the sole source of IPv4 addresses that can be used on the
> > global public Internet, it is IANA. IANA normally delegates the job of
> > allocating IP addresses to other registries although it does sometimes
> > allocate addresses directly. There are currently three such registries.
> 
> Ok, so there is an agreement among the registries to divide the "market" 
> into geographic areas.  And in each geographic area there is but one place
> where one can go to get an address block. 

It's not a market. In any geographic area there are hundreds of places
that you can go to get an IP address block. In North America there are
approximately 3,500 commercial ISP's and most of them will be able to give
you an IP address block with the addresses you need to connect your
network to the Internet. Or a company can choose to use private network
addresses from RFC1918 and connect to the Internet through a firewall
proxy as I have done with my home network. This only requires a single
routable IP address for the proxy rather than an entire block of them and
allows the company to implement security measures at the firewall proxy to
protect against hackers.

> That only reinforces the notion that there are anti-competitive forces
> afoot.

I agree. However, since your premise is wrong, so is your conclusion.

> > ... The contract they have with Network Solutions Inc. will
> > expire in 1998 and it will not be renewed.
> 
> I wish I could be so sure... who in NSF or otherwise in a position to make
> this happen has said that there will be no renewall?

There was a meeting of the Federal Networking Council Advisory Committee
last October at which this was discussed. Backround material on the FNC
and FNC-AC is available at http://www.fnc.gov and the minutes of the
meeting are at http://www.fnc.gov/FNCAC_10_96_minutes.html 
While the second recommendation at the meeting specifically addresses the
domain name registry functions of the Intrenic and not the IP registry
functions, we have been informed on this list that NSF funding for the IP
registry has already been terminated. One of the people attending the
FNC-AC meeting wrote a more detailled account of the discussion at
http://www.ar.com/newdom/2278.html

> > Even today before ARIN has been formed there are organizations that have
> > bypassed the Internic and received network addresses directly from IANA.

> For the most part, however, it is a near impossibility for most businesses
> to go directly to IANA and not be referred right back to the internic.

That's because even the IANA does not sell IP addresses. They are
allocated to people who can demonstrate a need for the addresses either
for themselves or for their customers. It is only in rare circumstances
that a company can demonstrate a need for IP addresses which cannot be met
by their ISP or RIPE or APNIC or the Internic.

> > I think I have quite clearly demonstrated that you are wrong on this
> > point. The website at http://www.arin.net contains a reading list that you
> > should read to familiarize yourself with before making such innaccurate
> > and inflammatory comments.

> What is becoming clear is that ARIN addresses are not guaranteed to be
> coordinated with routing in any way.

No IP address registry gives out addresses that are guaranteed to be
coordinated with routing. That is not their job. Some organizations which
need globally unique IP addresses, do not need them to be routed on the
global Internet. And the policies regarding IP allocation are not set by
the registries but by the international Internet community under the
auspices of the IETF. Those policies have, in the past, been modified
based upon the realities of the way in which network backbone operators
were allowing those addresses to be used. Some of this would be apparent
if you would read through the material referenced on the website. 

> Which only raises the question -- if what ARIN gives isn't routable, then
> what good is ARIN at all?

For some organizations, ARIN is a very useful and critically important
part of the Internet infrastructure. For others, ARIN is irrelevant since
it will not affect them any more that the development of new standards for
concrete mixes to be used in highway construction. Some people are greatly
concerned about the infrastructure underlying everyday life, others just
want it all to work without much thought. Take your pick.

> In other words, why should one pay ARIN money to obtain a block of numbers
> which might turn out to be useless?

ARIN is not exchanging blocks of IP addresses for money. ARIN *IS*
carrying out a critical infrastructure role and that role costs money. It
seems logical to carry out that role and to fund that role in a manner
similar to the way the rest of the world does so. In other words, the 
organizations that depend upon the resource being managed wisely will pay
to join ARIN and see that the resource is managed wisely. ARIN could set
its membership fees based upon an organization's gross annual revenue but
it is simpler and fairer to set the fee based upon an organization's
current usage of IP address space.

> As a practical matter, I'm pretty sure that this won't happen.  However,
> it does mean that after I get my numbers from ARIN, I'm going to probably
> have to pay yet another fee to yet another organization to get those
> numbers "activated".
> 
> How many gauntlets are ISPs going to have to run?

The ISP industry already has one of the lowest barriers to entry of any
other industry known to man other than prostitution. Any high school kid
can come up with the money and th knowhow to build a successful and
profitable ISP business. I've run across several in the USA and one in
Australia who have done so. There really are no gauntlets to run other
than learning how things work so you don't thrash around in the dark
tilting at windmills. And there are abundant resources available on the
Internet for ISP's who are ready to learn such as
http://www.amazing.com/internet or http://www.ispc.org

> > ARIN itself will be the regulatory authority and will be subject to direct
> > control by all organizations who receive IP address allocations since they
> > will be the members of ARIN.
> 
> Your sense of what consitutes "regulation" is rather odd.  In my country,
> any organization which has monopoly status over a resource is usually
> subject to some degree of public oversight, not just "regulation by its
> membership".

I would counter with the American Medical Association in which medical
doctors basically regulate themselves without much if any government
oversight. I believe accountants and lawyers do the same. It seems to be
a fair model to make those industries pay the freight for policing
themselves.

> > I notice that you copied the antitrust people at the US Department of
> > Justice
> 
> I didn't start this thread, I'm just keeping the cc list.

Me too. And I'm keeping the DoJ audience in mind as I write my replies
because they can't be expected to be familiar with the background of this
whole issue. Quite frankly, if the AOP hadn't flown off the handle and
started issuing misleading press releases and press interviews, this whole
thing would not be an issue. It was the AOP that got everyone believing
that there was to be some sort of new outrageously high fee for all IP
addresses when this is simply not true at all. And even the proposals on
the ARIN website are only proposals. They could be changed beyond
recognition by the time that the prospective members of ARIN actually
start signing up.

> > why they would have jurisdiction over an international organization such
> 
> An "international organization" is not immune from national laws.
> 
> Shell Oil may be an "international organization" but that doesn't block
> national jurisdiction. 

ARIN is more like the ITU-T than like Shell Oil in that ARIN is not a
profit-making corporation but is a non-profit industry consortium. I think
it's quite positive that the IETF and IANA want to foster a decentralized
model of IP registries for each continent rather than focusing the whole
task in a single organization in Geneva Switzerland. Eventually, RIPE,
APNIC and ARIN will be joined by a South American and an African IP
registry.

Michael Dillon                   -               Internet & ISP Consulting
Memra Software Inc.              -                  Fax: +1-250-546-3049
http://www.memra.com             -               E-mail: michael at memra.com





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