On Jun 6, 2014, at 7:57 AM, Mike Burns <[email protected]> wrote:

> Hi Larry,
> 
> "Personally I suspect that without needs testing the "haves" would have had 
> it all a long time ago.
> I have felt the same frustration, as a small provider, trying to meet the 80% 
> requirement can be almost
> impossible without gaming the system due to numerous small holes in a small 
> allocation.
> That said, I worry about any company that could purchase a couple of Billion 
> dollars of IPV4."
> 
> What is being expressed here is a fear of hoarding in the absence of a needs 
> test. A couple of billion dollars of IPv4 at current prices would yield about 
> 15 /8s. Even if some company wanted to risk those funds with IPv6 transition 
> threatening to erase them, there is no single seller who could offer 15 /8s, 
> nor would the sequestration of 15 /8s destroy the market, since this amount 
> represents just 25% of the estimated market size of 1 billion addresses. 
> Since the buyer and seller will be disclosed and registered under any 
> no-needs policy, there is little threat of a stealthy move here, and any 
> buyer seeking to corner or manipulate the market knows he does so at the 
> peril of forcing the IPv6 transition.  The best protection against this is 
> continued work towards IPv6 and the establishment of a reliable, open, and 
> global IPv4 market with at least the same level of transparency into 
> registration as we have now.  As a broker, I actively sought out speculators 
> to bid for addresses in the Nortel sale. This was a prime opportunity to 
> acquire 660,000 addresses at the floor of the market, but it was regarded as 
> too risky by almost all. In the intervening years I became aware of other 
> opportunities to acquire address space without needs tests, but I never found 
> anybody interested in buying addresses on pure speculation. In any case, this 
> fear can only reasonably be expressed in the context of a complete removal of 
> needs tests, and could not be applied to a more limited removal of the needs 
> test such as that proposed in 2014-14.

Finding 4 actors who want to corner the market probably wouldn’t be very hard. 
Since 25% is 1/4 of the projected market size, I would say that the rest of 
your argument is on pretty shaky ground.

> "Many of us fear that if need is not considered in the transfer market the 
> little guys will find that none is available at any price."
> 
> We are three years into the open, post-Microsoft/Nortel market and there is 
> no evidence of hoarding in my experience. I have never fielded a phone call 
> or email from any company or individual seeking addresses they didn't plan to 
> utilize at some point, although I have fielded plenty from people seeking 
> addresses that for whatever reason ARIN policy would prohibit them from 
> registering. Perhaps other brokers on the list might report on their 
> experiences.

Address space is still available nearly for free from ARIN, especially for 
smaller organizations, so this isn’t a real test of what will happen post 
runout and any claim that it is is absurd.

> "Like it or not the big guys have an advantage. Let's make sure that 
> "cornering the market" isn't one of them."
> 
> Little guys benefit from the dropping of needs test for small transfers. No 
> need to navigate the ARIN process if you just need a /24 and you can't get 
> one from your upstream, or not at a reasonable cost, or because you feel more 
> secure with your own space, or because you don't wish to game the system. 
> Support of 2014-14 would allow small companies to  have this option while 
> preventing hoarding or speculation through limits on size and number of 
> transfers.  Perhaps you care to comment on whether you might consider support 
> of 2014-14 at the current size of /16 or at another size that you might feel 
> more appropriate?

Again, this is your perspective, but it’s not necessarily entirely true. It’s 
only true if you assume that the market will have a continuous supply and 
demand will be lower than supply. I would argue that the number of inter-RIR 
transfers to the APNIC region which have already been processed would indicate 
that after exhaustion, this is unlikely to be a persistent state or even last 
very long at all.

Owen

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