So I thought Jose’s email was very spot on.

But I question the relevance of ANY distinction between ISP and End-user in 
2016.   In what way does the operator community benefit from a difference in 
rules (especially wrt Whois)?  If we put aside the ARIN billing issue, and look 
at it purely from an inter-operator perspective, why is it good that ARIN 
policy and procedures differentiate between ISPs and End-users?

Genuinely curious.

David R Huberman
Principal, Global IP Addressing
Microsoft Corporation

From: [email protected] [mailto:[email protected]] On Behalf 
Of Owen DeLong
Sent: Sunday, December 6, 2015 3:42 PM
To: Jose R. de la Cruz III <[email protected]>
Cc: [email protected]
Subject: Re: [arin-ppml] Proposal ARIN-2015-8

Not speaking for John, but I don’t believe that would help because I believe 
that anything which
does not meet the definition of an “end user” is de fact an ISP.

Creating a clear definition of “ISP” would likely, instead, create a new 
category of organizations
which fit neither defined category and suddenly find themselves without any way 
to interact with
ARIN. I would not consider that to be an improvement.

It may be that adding a statement to policy that any organization which does 
not meet the strict
definition of “End User” is therefore considered an ISP for policy purposes.

Owen

On Dec 6, 2015, at 13:03 , Jose R. de la Cruz III 
<[email protected]<mailto:[email protected]>> wrote:

John:
Thanks for the additional info. It looks like the problem brought forth in the 
referenced document was never completely solved. Because an end user is defined 
as "an organization receiving assignments of IP addresses exclusively for use 
in its operational networks.", it is my opinion that the "exclusively" part of 
the definition maybe the one creating some problems. In the "large enterprises 
which may provide services to many entities of various degrees of affiliation" 
example,  the exclusively part of the definition should not apply. The question 
is, are these organizations actively involved in the reassigning that IP space 
to their customers?

Although no formal definition for ISP is included in the policy manual, an ISP 
does not fit into the end user definition. Would a definition for ISP provide a 
clear guidance in thesubject? How should hosting/cloud/cdn providers be 
categorized?
José

On Fri, Dec 4, 2015 at 8:43 AM, John Curran 
<[email protected]<mailto:[email protected]>> wrote:
On Dec 4, 2015, at 6:48 AM, Jose R. de la Cruz III 
<[email protected]<mailto:[email protected]>> wrote:

RE: ARIN-2015-8

4.     Should End-Users who want to be able to re-assign records simply be 
required to become ISPs?
--->No. Why should they?
5.     Should the ISP/End-User distinction be eliminated (which is a bigger 
discussion outside the scope of the current problem statement)?
---> No. They are different type of business entities and should be serviced 
according to their needs.

I have no comment either way regarding the particular policy proposal under
discussion, but would like to provide some background that may aid in further
consideration of the question:

- The distinction between “end-user” and “ISP” is very clear in many cases,
  but not universally.  Examples where it is less clear include university and
  college systems, large enterprises which may provide services to many
  entities of various degrees of affiliation (wholly-owned, partially-owned,
  joint entity, business partner), hosting/cloud/cdn providers (where the line
  between infrastructure and customer can be quite blurry at times), etc.

- The desire to between ISP and End-User (or visa-versa) may be driven
   by fee or policy motivations, but we have seen an increase in end-users
   who wish to re-assign blocks in order to have more accurate information
   in the database regarding the actual address usage, particularly with
   respect to their geolocation data.

Today ARIN tries to work with ISPs and end-users who wish to change
their categorization, but understandly we lack clear guidance for what
is becoming an increasingly blurry distinction.   For additional context,
refer to the ARIN 31 Policy Experience Report (where this issue was
raised) - 
https://www.arin.net/participate/meetings/reports/ARIN_31/PDF/monday/nobile_policy.pdf

Thanks!
/John

John Curran
President and CEO
ARIN




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