I think John's message, with its new info that speculators call him regularly to learn the rules, leads to a fairly straightforward conclusion:
2014-14 would work nicely. -get a "free" 8.3 transfer up to a /16 -anything more requires strict needs basis <mechanism TBD> -throw in a clause that ARIN has the right to refuse if it believes the free transfer is not being made in good faith because of speculation and multiple OrgIDs This makes life easy for non-big guys. It deters speculation. It keeps needs basis for those with all the money. What's the counter argument against 2014-14? David R Huberman Microsoft Corporation Principal, Global IP Addressing ________________________________________ From: John Curran <[email protected]> Sent: Wednesday, September 24, 2014 4:54:38 AM To: David Huberman Cc: [email protected] List ([email protected]) Subject: Hoarding and speculation (was: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification) On Sep 23, 2014, at 10:45 PM, David Huberman <[email protected]> wrote: > What is the virtue of a limit? > > It's not the prevention of speculation and hoarding. Those will always > happen outside the view of ARIN policy. > ... > Before anyone answers this, please ensure you're knowledgeable about > the IPv4 market today. I am. > ... > There's no speculation that I can find, short of a one-off speculator > who is a well-known fraudster. > ... > ARIN's job should simply be to verify the seller is the bona fide registrant, > and that the seller agrees to the transfer, and that the buyer signs an > RSA and pays whatever fees are necessary to cover the costs of the > transaction processing. David - You describe an interesting "present state", and presuming it is well-informed, it is probably extracting and making explicit some points in your worldview before continuing the discussion. You indicate - 1) Hoarding and speculation can happen outside of ARIN's view This is almost certainly the case, as parties always free to contract for future behavior, including a party ceding its ability to transfer address rights to any other party. 2) A limit on the size of transfers cannot meaningfully deter hoarding, due to point #1 above. 3) A limit on the size of transfers cannot meaningfully deter speculation, due to point #1 above. 4) Hoarding does occur, but there is no meaningful speculation that you can find. By "hoarding", I believe that you mean parties obtaining right to number resources in anticipation of future need to make use of them, as opposed to "speculation" whereby one obtains rights in anticipation of financial gain. If you are correct above, it does raise the question of "why isn't there abundant & apparent speculation going on today?" It can't be for lack of interest; investment firms will speculate on nearly anything that has good potential to beat the market. I've had investment firms ask about the 'rules and regulations' that apply to transfers of IP address rights for this very reason. The various policy merits of allowing hoarding or speculation are not mine to argue; that is for the community to ponder through the policy development process. However, you propose that we simplify ARIN processes and make ARIN policy fit reality; effectively that ARIN's job should simply be to verify the seller is the bona fide registrant and that parties agree to the transfer. If community does as you suggest, both hoarding and speculation become readily available, and this represents a significant change from the present state as described by your worldview. A change which simply formalized the present state that you describe would not enable speculation, since you do not view that as abundant in the present system. The difference between the two outcomes comes down to whether or not the buyer is obtaining the resources in anticipation of future need or simply financial gain, i.e. is the buyer of the rights to the addresses a bona fide network operator. I'll assert that the present system is actually rather unfavorable to speculation; parties that seek to obtain the rights to address blocks without the real potential for future use are run a very risk of ending up in violation of policy and with impaired investments as a result. More specifically, your postulate [#3] above to the effect that a limit on the size of transfers cannot meaningfully deter speculation is likely not valid - the limit does indeed deter speculation today, as having to qualify eventually against needs- based limit requires the party to actually operate a network (or risk total loss of the investment, likely beyond the risk profile of the vast majority of potential investors.) Unless you are advocating for a policy shift to enable speculation, simplification of ARIN policy towards your "present reality" needs to be more than simply verifying that the seller is the bona fide registrant and that parties agree to the transfer; in particular, verification that the recipient is a bona fide network operator would also be required. That is an aspect presently implied in the needs-based limit on the size of an address rights transfer, but that element could be made explicit and retained, if limit itself is otherwise undesirable in your view. Interesting discussion - Thank you! /John John Curran President and CEO ARIN _______________________________________________ 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.
