I advise several large legacy block holders. Some of them signed the LRSA, but many have not. For them, the burdens imposed by the LRSA outweigh the benefits. Some on the PPML have suggested that off-contract legacy holders don't sign up with ARIN because they want to be free-riders. But the fees (and the avoidance of the fees) are not a factor in their LRSA decision.
Based on my experience working with legacy block holders, I believe adopting a policy substantially similar to RIPE 605 (ARIN prop 203) would go a long way in harmonizing the interests of the ARIN community with the community of legacy holders that do not have formal relationships with ARIN. ARIN's absolute control over additional allocations of "free" IPv4 numbers in its region has served as the primary policy enforcement mechanism. This carrot really only works on recipients that need more IPv4 numbers, and then only as long as ARIN has free numbers to give out. It doesn't directly influence the behavior of many legacy block holders when they convey their spare numbers. Legacy holders are a major source of future IPv4 number distributions, and their relevance to the broader ARIN community will become more prominent as ARIN's IPv4 free pool reaches depletion. In the secondary market context, ARIN now relies on its ability to withhold registry database updates as the primary means to extend enforcement of its current policies into private transactions between parties conveying beneficial use of IPv4 numbers. This, however, is a weak enforcement tool. Two parties can convey beneficial use of IPv4 numbers in lawful commercial transactions without updating ARIN's registry database. But IPv4 number conveyances not recorded in the registry system produces very undesirable results - the "reality" in the registry database will not reflect operational reality, as David Conrad and others have pointed out in several posts. Buyers and sellers would prefer to document their conveyances in a reliable and accurate public registry, but not if the contingencies and conditions materially and adversely affect their commercial arrangement. RIPE 605/ ARIN prop 203 recognizes this reality. With a little tweaking, adopting it would go a long way in minimizing the disincentives now facing legacy holders (and entities that want to acquire their numbers) when contemplating whether updating the registry database is worth the risk of subjecting their transactions to ARIN's approval process. Marc Lindsey Levine, Blaszak, Block & Boothby, LLP 2001 L Street, NW Suite 900 Washington, DC 20036 Office: (202) 857-2564 Mobile: (202) 491-3230 Email: [email protected]<mailto:[email protected]> Website: www.lb3law.com<http://www.lb3law.com>
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