On Jun 9, 2014, at 11:36 , Mike Burns <[email protected]> wrote: > Hi Owen, > > Thanks for your reply. Fears of hoarding and speculation don't apply to > 2014-14, unless you think that ARIN staff would be unable to discern a series > of spun-up holding corps with hidden ownership. In any case, our different > perspectives of the risks involved are not applicable to 2014-14, which I > know was not the context of your earlier post. And I would like to move the > discussion towards 2014-14 and away from fears of an unregulated market.
I have no reason to believe that they could not. However, I have also made my position on 2014-14 clear and I believe it carries other risks. I have proposed a compromise which I thought was acceptable and basically met the anti-needs crowd approximately half-way (proposed /16, I proposed /24, /20 seems about as "in the middle" as is feasible). > APNIC reinstated their needs test only because ARIN supply was held hostage, > I believe you may have been involved? I don't see it that way, but if you are asking if I was involved in the ARIN policy process and/or talking to APNIC about the issues at the time, then, yes, I was. I find your use of the term "hostage" offensive and inaccurate. > What's more, like ARIN's previous CEO and unlike ARIN's current CEO, RIPE > never took the position that RIPE policy applies to legacy space. So there > has always been a needs-free market for RIPE ERX space, but that market > remains untapped by speculators, both before and after RIPE exhaust. And, of > course, since needs are no longer tested for RIPE transfers, we can use RIPE > as our experiment to see if speculators attempt to take advantage of that. > RIPE publishes transfer statistics. Would you consider a review of those > statistics a reasonable way to discern the presence of speculators? Not until some time after the ARIN free pool is exhausted, no. > The idea that somebody would contact /23 and /24 holders in order to > speculate fills me with mirth. I kind of think a speculator would be more > efficient if he called a couple of brokers. I don't believe I said the speculators would necessarily not work through brokers. What makes you think I expect them to necessarily deal directly? Owen > > Regards, > Mike > > > > > -----Original Message----- From: Owen DeLong > Sent: Monday, June 09, 2014 1:30 PM > To: Mike Burns > Cc: [email protected] ; Steven Ryerse ; [email protected] List > ([email protected]) > Subject: Re: [arin-ppml] About needs basis in 8.3 transfers > > > On Jun 7, 2014, at 07:15 , Mike Burns <[email protected]> wrote: > >> Hi Owen, >> >> 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. >> >> >> It's not nearly so simple. First you would have to find four players willing >> to risk $8 billion dollars. Second you would have to have them create an >> inherently unstable cartel. Third you would have to find sellers with that >> much space, and this would likely mean hundreds of sellers at the least and >> a years-long endeavor. Fourth you would have to process those sales in a >> transparent market where your purchases are recorded for all to see. Fifth >> you would have to believe that there would be no reaction to this public >> information vis a vis price. Sixth you would also have to believe that these >> four billionaires ignored any risk of driving the IPv6 transition which >> would make their efforts worthless. Seventh you would have to ignore the >> fact that there are already methods of acquiring space without need which to >> my knowledge have not been used by speculators, and in fact there is zero >> evidence that speculators even exist. > > Nope, this doesn't have to be a cartel. It only has to be 4 or more actors > each willing to invest an average of $2b and each of whom wants to see as > many of their competitors as possible put at a substantial disadvantage in > the near term future of the access market. > > Now I realize that large $TELCOS and large $CABLECOS and such would never > engage in such anticompetitive practices and are staunch defenders of all > good things like network neutrality, free and open peering policies and > fantastic customer service with good bandwidth and fair prices. However, > since pretty much everything in that last sentence has been repeatedly proven > false, I don't think I'm on quite so shaky a ground after all. > > Your third item is absurd. If they don't find sellers with that much space, > then it means the market isn't as large as described and the problem is even > worse and market capture is even easier. Without a needs test or the other > restrictions in 8.3, it would not take years, it would take days. Address > space would be swept away as fast as it came available on the market. It > would be IP lotto for the uber-wealthy corporations. > > As to fourth, yes and no. What's so transparent if $MEGACORP spins up lots of > $IP_ADDRESS_HOLDING_CORPS just waiting to pounce on available space, much > like the test-the-waters orders placed in various markets and dark pools > looking for high-frequency trading victims? The stock market is allegedly > just such an open market and is rife with just this kind of gouging. > > As to 6, no, they just have to decide that the risk of said transition > occurring in less than time_T where T is their idea of investment recovery > time given the expected advantage is relatively low. That's not so far > fetched, since the average F500 corporation hasn't really started any sort of > transition in earnest and will likely need 2 or more years to actually > achieve a complete transition. > > Speculation in the face of an existing free pool is pretty nonsensical. > Further, the entities I would expect to engage in this kind of speculation > would likely consider it not worth the risk unless they can get the addresses > registered to them in the recognized registry. > >>> 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. >> >> >> Are you saying that my claim of never having heard from a speculator is >> absurd? Have you forgotten that APNIC and RIPE ran out years ago? (after >> which point they both dropped the needs test for transfers). > > Shortly after dropping the needs test, APNIC reinstated it. > > While you may not have heard from a speculator, others have. I have, in fact, > received offers from speculators even for my tiny little /23 and /24. > >>> 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 I have brokered more transfers to APNIC than anybody in the world. >> Nothing I said requires that there be a continuous situation where demand is >> lower than supply. However I can report without much understanding that >> there is indeed more supply than demand in the transfer market today, based >> on my own experiences and those I have heard from other brokers. > > I don't doubt that today as there remains a free pool in the ARIN region. I > do not see that persisting more than a year or so with needs basis in place > and even faster if needs basis is removed once the ARIN and LACNIC free pools > are exhausted. > > Owen _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
