Re: David's >>>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..end quote.
+1 on the above ..from data offerings and knowledge gleamed so far. But a free /16...as opposed to a smaller one..?? RD skype: rudidaniel On Sep 24, 2014 9:49 AM, <[email protected]> wrote: > Send ARIN-PPML mailing list submissions to > [email protected] > > To subscribe or unsubscribe via the World Wide Web, visit > http://lists.arin.net/mailman/listinfo/arin-ppml > or, via email, send a message with subject or body 'help' to > [email protected] > > You can reach the person managing the list at > [email protected] > > When replying, please edit your Subject line so it is more specific > than "Re: Contents of ARIN-PPML digest..." > > > Today's Topics: > > 1. Re: Draft Policy ARIN-2014-20: Transfer Policy Slow Start and > Simplified Needs Verification (Matthew Kaufman) > 2. Hoarding and speculation (was: Re: Draft Policy ARIN-2014-20: > Transfer Policy Slow Start and Simplified Needs Verification) > (John Curran) > 3. Re: Draft Policy ARIN-2014-20: Transfer Policy Slow Start and > Simplified Needs Verification (Mike Burns) > 4. Re: ARIN-2014-20 and current future looking needs assessment > (Martin Hannigan) > 5. Re: Hoarding and speculation (was: Re: Draft Policy > ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs > Verification) (David Huberman) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Tue, 23 Sep 2014 19:50:53 -0700 > From: Matthew Kaufman <[email protected]> > To: David Huberman <[email protected]> > Cc: "[email protected] List \([email protected]\)" > <[email protected]> > Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy > Slow Start and Simplified Needs Verification > Message-ID: <[email protected]> > Content-Type: text/plain; charset=us-ascii > > Speculators and hoarders could already be locking up space via contracts > that aren't even transfers (yet)... And yet I haven't seen much of that > going on either. In fact, offers to buy or lease (or any other contract > regarding) space are coming in less often than a year ago, if anything. > > Matthew Kaufman > > (Sent from my iPhone) > > > On Sep 23, 2014, at 7:45 PM, David Huberman < > [email protected]> wrote: > > > > John wrote: > > > >> A transfer policy mechanism which allows receipt up to a limit based on > >> current holdings provides far more certainty for those who wish to plan > >> for the future, as they can go to market knowing precisely that limit. > > > > 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. Speculators and hoarders will > > buy blocks on the open market and simply not engage ARIN because > > there's no reason to. Contract law makes it trivial to ignore ARIN. > > > > It's not conservation - there is no such thing as conservation in IPv4. > > 85% of the address space ARIN issued over the last 10 years went > > to less than 20 companies. (At a significant penalty, I might add, to > > the little guys and especially new entrants, who got screwed in ARIN > > policy for 17 years.) > > > > Before anyone answers this, please ensure you're knowledgeable about > > the IPv4 market today. I am. I characterize it as VERY robust. Tons of > > supply, with new suppliers showing up every month. Outside of China, > > prices are low; it's a buyer's market. There's no speculation that I can > > find, short of a one-off speculator who is a well-known fraudster. There > > is certainly hoarding by the larger companies, but ARIN policy today > > isn't stopping that, and no policy passed here can stop that. Think about > > that last sentence carefully. ARIN policy is powerless to stop hoarding. > > > > So how do we write policy that helps the non-big guys? By removing > > artificial policy barriers that require lots of paperwork with ARIN > beyond > > simply, "I bought this /20 from this company, please update Whois". > > > > 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. > > > > Let's simplify ARIN processes, make ARIN policy fit the REALITY of > > network operations in a post-exhaustion world, and move on with > > talking about RPKI, DNSSEC, IPv6 and other actually important things > > that will shape our future. > > > > David > > _______________________________________________ > > 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. > > > ------------------------------ > > Message: 2 > Date: Wed, 24 Sep 2014 11:54:38 +0000 > From: John Curran <[email protected]> > To: David Huberman <[email protected]> > Cc: "[email protected] List \([email protected]\)" > <[email protected]> > Subject: [arin-ppml] Hoarding and speculation (was: Re: Draft Policy > ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs > Verification) > Message-ID: <[email protected]> > Content-Type: text/plain; charset="us-ascii" > > 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 > > > > > > > > > > ------------------------------ > > Message: 3 > Date: Wed, 24 Sep 2014 07:52:52 -0400 > From: "Mike Burns" <[email protected]> > To: "David Huberman" <[email protected]>, "John Curran" > <[email protected]> > Cc: [email protected] > Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy > Slow Start and Simplified Needs Verification > Message-ID: <D94590F128074A84AB76B5BDC495C573@ncsscfoipoxes4> > Content-Type: text/plain; format=flowed; charset="iso-8859-1"; > reply-type=original > > Hi list, > > +1 to what David wrote. > > I would say it is a buyer's market, there are more sellers than buyers. > Also demand for transfer IPv4 is not as high as demand for free pool IPv4 > in > the previous years. > I believe this is due to companies being a litle more efficient internally. > And there have been some fairly large CGN deployments as well. > > I see no evidence of speculation in transfers, even in RIPE after they > effectively dropped needs tests for transfers. > That last sentence should provide relief for those who have expressed this > fear and expectation. > > I wouldn't call it robust yet, as there are still too few buyers. > > I agree that ARIN should become a lightweight registry service for IPv4, > concentrating on our primary stewardship goal of registration and avoiding > policy which works against accurate registration in the name of > conservation > which is already provided by the natural forces of a market. > > This will be cheaper for ARIN, easier for everyone to understand, consonant > with property law, result in faster transfers, a more accurate registry, > less verbose NRPM, reduce corruption potential, and free us for policy > development in other areas. > > Regards, > > Mike > > > > > > > ----- Original Message ----- > From: "David Huberman" <[email protected]> > To: "John Curran" <[email protected]> > Cc: <[email protected]> > Sent: Tuesday, September 23, 2014 10:45 PM > Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow > Start and Simplified Needs Verification > > > > John wrote: > > > >> A transfer policy mechanism which allows receipt up to a limit based on > >> current holdings provides far more certainty for those who wish to plan > >> for the future, as they can go to market knowing precisely that limit. > > > > 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. Speculators and hoarders will > > buy blocks on the open market and simply not engage ARIN because > > there's no reason to. Contract law makes it trivial to ignore ARIN. > > > > It's not conservation - there is no such thing as conservation in IPv4. > > 85% of the address space ARIN issued over the last 10 years went > > to less than 20 companies. (At a significant penalty, I might add, to > > the little guys and especially new entrants, who got screwed in ARIN > > policy for 17 years.) > > > > Before anyone answers this, please ensure you're knowledgeable about > > the IPv4 market today. I am. I characterize it as VERY robust. Tons of > > supply, with new suppliers showing up every month. Outside of China, > > prices are low; it's a buyer's market. There's no speculation that I can > > find, short of a one-off speculator who is a well-known fraudster. There > > is certainly hoarding by the larger companies, but ARIN policy today > > isn't stopping that, and no policy passed here can stop that. Think about > > that last sentence carefully. ARIN policy is powerless to stop hoarding. > > > > So how do we write policy that helps the non-big guys? By removing > > artificial policy barriers that require lots of paperwork with ARIN > beyond > > simply, "I bought this /20 from this company, please update Whois". > > > > 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. > > > > Let's simplify ARIN processes, make ARIN policy fit the REALITY of > > network operations in a post-exhaustion world, and move on with > > talking about RPKI, DNSSEC, IPv6 and other actually important things > > that will shape our future. > > > > David > > _______________________________________________ > > 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. > > > > > > ------------------------------ > > Message: 4 > Date: Wed, 24 Sep 2014 14:27:44 +0200 > From: Martin Hannigan <[email protected]> > To: Owen DeLong <[email protected]> > Cc: "[email protected]" <[email protected]> > Subject: Re: [arin-ppml] ARIN-2014-20 and current future looking needs > assessment > Message-ID: > <CAMDXq5P_ySx9aC5Kkfyq93ry3MfGr1dnNUA5DgO7Rg4gmF= > [email protected]> > Content-Type: text/plain; charset=ISO-8859-1 > > On Wed, Sep 24, 2014 at 1:59 AM, Owen DeLong <[email protected]> wrote: > > You have always been able to get space from ARIN based on forward-looking > > business cases, but it has been limited. > > > > This applies to both free pool and transfers equally, though free pool > being > > limited to a 3-month window now for ISPs makes "forward" a little less > > useful. > > > Business plan is a useless term in this context. My earlier point > which may not have been clear was that ARIN is not qualified to > evaluate a business plan let alone compare my business plan to a > competitors and make judgements as to what my (or their) need is. If > they did do such a thing, it would be problematic. The three month > window is a market limit not so much of a business limit unless ARIN > unevenly applies the policies (which in my own view, they do). > > So with that said, yes, I agree, it applies to both free pool and > transfer requests. > > > > > > I would venture that most end-user initial allocations are based on at > least > > somewhat forward-looking projections. > > All submissions regardless of who submits them follow this theme. You > tell ARIN what you want. They guess if its credible or not, then > assign what you need or figure out what policy to use to avoid > fulfilling the request. > > > > Best, > > -M< > > > ------------------------------ > > Message: 5 > Date: Wed, 24 Sep 2014 14:48:40 +0000 > From: David Huberman <[email protected]> > To: John Curran <[email protected]> > Cc: "[email protected]" <[email protected]> > Subject: Re: [arin-ppml] Hoarding and speculation (was: Re: Draft > Policy ARIN-2014-20: Transfer Policy Slow Start and > Simplified Needs > Verification) > Message-ID: > < > dd33d38ad67b4bcea4ac0ecba4fbd...@dm2pr03mb398.namprd03.prod.outlook.com> > > Content-Type: text/plain; charset="us-ascii" > > 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 > > > > > > > > > > ------------------------------ > > _______________________________________________ > ARIN-PPML mailing list > [email protected] > http://lists.arin.net/mailman/listinfo/arin-ppml > > End of ARIN-PPML Digest, Vol 111, Issue 60 > ****************************************** >
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