It all sounds good in theory but it is pretty much impossible to enforce a ban on leasing IP space to another organization. If AT&T has a very large customer who wants to lease a /20 and AT&T has it and wants to lease it to them, it’s the exact same thing as if a company we’ve never heard of wants to lease it to another organization. Somehow trying to put limitations on it like it has to be leased in concert with another service sounds good, but there really isn’t any way for ARIN to enforce that – and that hasn’t been a requirement up until now.
Nobody wants fraud as it hurts all legitimate providers sooner or later, but the real world of tying policy in knots to try to prevent fraud has the strong likelihood of stopping legitimate providers from offering legitimate services. The best that can be done is try to have reasonable policies to try and prevent fraud at the time of application for number resources. If we can learn from the recent fraud case to tighten up the application process and at the same time allow legitimate providers to get resources then we’ve done all we can really do in the real world. I find the discussion of trying to find a maximum size like a /19 or /20 or /21 unreasonable. I remember not so long ago T-Mobile came to ARIN looking for a /8. I assume they legitimately needed it and ARIN helped them get something like ¾ of a /8 in multiple blocks. We were not at runout yet but of course that amount of resources speeded up the runout timeframe. I think that any organization should be able to get on the waiting list for any size block from /8 up. Obviously ARIN can’t award a very large block if it doesn’t have the space to begin with, but conceptually why would a request for a /8 from a legitimate provider like T-Mobile not be any more valid than a request for a /20 from a smaller legitimate provider – assuming that they can justify their need per existing or improved policy? I get it that setting a maximum of a /19 or /20 or /21 might give resources to more providers, but in my opinion what is the real argument that a larger bock request shouldn’t be valid. ARIN should do the best they can to help all providers with resources they can justify. That is actually the fairest policy of all. I’m probably speaking to deaf ears out there about fairness but that’s my two cents. Cheers! Steven Ryerse President 100 Ashford Center North, Suite 110, Atlanta, GA 30338 www.eclipse-networks.com<http://www.eclipse-networks.com> 770.656.1460 - Cell 770.399.9099- Office [Description: Description: Eclipse Networks Logo_small.png]℠ Eclipse Networks, Inc. Conquering Complex Networks℠ From: ARIN-PPML <[email protected]> On Behalf Of Robert Clarke Sent: Wednesday, May 29, 2019 4:49 PM To: [email protected] Cc: arin-ppml <[email protected]> Subject: Re: [arin-ppml] Waiting List IPv4 blocks transferred after issuance Hi Hayee, A legitimate ISP leasing their space is of course is legal. In this case I'm talking about bad actors who provide false information to ARIN to get large block sizes, and then turn around and lease them to third parties. My point is that transferring/selling IPv4 blocks is not the only way to make a large amount of money by providing fraudulent information to ARIN. For this reason it does not make sense to use the transfer/block size information that John provided as validity that a /19 or lower somehow leads to less fraud. Thanks, Robert Clarke M: +1 (425) 442-6485 On May 29, 2019, at 1:38 PM, Hayee Bokhari <[email protected]<mailto:[email protected]>> wrote: Robert, If the IP belongs to an ISP or a Network provider then every ISP or Network carrier always lease their IP's to their clients, that does not make it illegal, that is their business. Thanks Hayee Hello Mike, Why are you using John's "waiting list IPv4 blocks transferred" numbers as a baseline for the /19 numbers? This is completely arbitrary and doesn't give any scale as to the problem with fraud. See my earlier reply to John's email in the other thread: "Thanks for sharing. I'd like to note that it can be dangerous to use the blocks transferred via 8.2/8.3/9.4 as a metric for abuse. A fraudster that gets past ARIN's scrutiny and obtains IPs with fraudulent information is probably smart enough to lease their IPs as opposed to selling the space outright. There is a huge market for leased space, and those deals happen behind closed doors with no oversight from ARIN. IP addresses go for $0.2-0.5/mo depending on term/IP reputation/size which could lead to $XX,XXX in illicit revenue with no risk of ARIN's scrutiny which would normally occur during the transfer process." Thanks, Robert Clarke On May 29, 2019, at 8:13 AM, Mike Burns <[email protected]<mailto:[email protected]>> wrote: Hi Fernando, Thanks for the discussion. Many feel as you do, that unused addresses should be returned to ARIN for subsequent distribution to those in need. Unfortunately, that policy was not successful in bringing unused addresses into actual use by those in need. The community decided to harness the profit motive to incentive this process, and by all accounts it is working. Unfortunately the profit motive also incentivizes fraudulent plundering of the waiting list pool. So I am happy to discuss the correct balancing of things to prevent fraud but allow the market to continue to drive us towards the desirable ends of accurate registration and efficient use. Since the /19 is the threshold number of sorts for flipping, I could accept a /20 as the maximum size. I think a 2 year wait is reasonable, but I don’t see the additional benefit as worth the distinction of ARIN space into more classes. And making it more complicated with multiple waiting periods is even less desirable, IMO. Regards, Mike From: ARIN-PPML <[email protected]<mailto:[email protected]>> On Behalf Of Fernando Frediani Sent: Wednesday, May 29, 2019 10:50 AM To: [email protected]<mailto:[email protected]> Subject: Re: [arin-ppml] Waiting List IPv4 blocks transferred after issuance On 29/05/2019 11:31, Mike Burns wrote: Orgs will wait out any period, sitting with unused addresses until they reach the resale date. Not efficient use. If it's not a legacy resource and if ARIN gets to know about it, it may just recover this addresses even if the resource holder is paying it correctly. That's how it should work. People will lease unused addresses to others and Whois accuracy will suffer if they can’t resell them. Not accurate registration. If people lease they prove they have no use for the addresses and again ARIN should recover them at any time. If whois is inaccurate, well it is their fault and not policies fault. They must bind to the current rules not the other way round. I think we should give everybody currently on the list up to a /19 and then restrict new entries to a /22. Fair to discuss this scenario, although I still think /19 is too much. Agree on /22 for new entries. I think a 5 year resale wait is too long, based on the paltry resales of prior waiting-list subnets smaller than /19. It may be long, but 2 years seems a little short and 'acceptable' for a fraudster. Perhaps something in between. I support a /22 restriction for new entrants, a /19 max for current list members, and maintenance of the 12 month wait for simplicity’s sake. What about discuss /22 for new entrants, /20 for current list members and 36, 42 or 48 months for transfers ? Seems more reasonable in my view and cover most aspects of this discussion. Regards, Mike From: ARIN-PPML <[email protected]><mailto:[email protected]> On Behalf Of Fernando Frediani Sent: Wednesday, May 29, 2019 8:51 AM To: [email protected]<mailto:[email protected]> Subject: Re: [arin-ppml] Waiting List IPv4 blocks transferred after issuance +1 On 28/05/2019 23:52, Owen DeLong wrote: Mike, Yes and no. I believe that the lack of legacy holders for any blocks issued under 4.1.8 reduces the need for the market. Defunct organizations can easily be reclaimed in this space because they stop paying their ARIN bill. Eliminating the resale value of these addresses won’t really encourage squatting on them and limiting the size of organization and size of block that can benefit from 4.1.8 further helps to reduce the potential for hoarding. I realize that as a broker, any address that can’t be monetized is a lost opportunity for your organization, but I think there’s plenty of addresses out there that haven’t been processed through 4.1.8, so I don’t think limiting the resale potential of such blocks to reduce fraud is a bad idea. Owen On May 28, 2019, at 12:46 , Mike Burns <[email protected]<mailto:[email protected]>> wrote: The percentages of blocks transferred takes a significant leap at the /19 size. Below that, the percentages are all below 7%. At /19 and above, the percentages are all above 21%. Seems like a natural demarcation for maximum block size, but prices do continue to rise. While we want to fight fraud, we should still remember the underlying reasons for the Ipv4 transfer market apply to these addresses as well. That is, the market provides incentives for efficient use and accurate registration. Regards, Mike From: ARIN-PPML <[email protected]<mailto:[email protected]>> On Behalf Of John Curran Sent: Tuesday, May 28, 2019 1:53 PM To: ARIN-PPML List <[email protected]<mailto:[email protected]>> Subject: [arin-ppml] Waiting List IPv4 blocks transferred after issuance Importance: High Folks - It occurred to me that it might be useful to have a quick summary of waiting list blocks issued and subsequently transferred. Attached is the distribution (count per prefix size) of all blocks that have been issued via ARIN's waiting list policy and subsequently transferred via NRPM 8.2/8.3/8.4 policy. FYI, /John John Curran President and CEO American Registry for Internet Numbers <image001.png> _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]<mailto:[email protected]>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected]<mailto:[email protected]> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]<mailto:[email protected]>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected]<mailto:[email protected]> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]<mailto:[email protected]>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected]<mailto:[email protected]> if you experience any issues. Hello Mike, Why are you using John's "waiting list IPv4 blocks transferred" numbers as a baseline for the /19 numbers? This is completely arbitrary and doesn't give any scale as to the problem with fraud. See my earlier reply to John's email in the other thread: "Thanks for sharing. I'd like to note that it can be dangerous to use the blocks transferred via 8.2/8.3/9.4 as a metric for abuse. A fraudster that gets past ARIN's scrutiny and obtains IPs with fraudulent information is probably smart enough to lease their IPs as opposed to selling the space outright. There is a huge market for leased space, and those deals happen behind closed doors with no oversight from ARIN. IP addresses go for $0.2-0.5/mo depending on term/IP reputation/size which could lead to $XX,XXX in illicit revenue with no risk of ARIN's scrutiny which would normally occur during the transfer process." Thanks, Robert Clarke On May 29, 2019, at 8:13 AM, Mike Burns <[email protected]<mailto:[email protected]>> wrote: Hi Fernando, Thanks for the discussion. Many feel as you do, that unused addresses should be returned to ARIN for subsequent distribution to those in need. Unfortunately, that policy was not successful in bringing unused addresses into actual use by those in need. The community decided to harness the profit motive to incentive this process, and by all accounts it is working. Unfortunately the profit motive also incentivizes fraudulent plundering of the waiting list pool. So I am happy to discuss the correct balancing of things to prevent fraud but allow the market to continue to drive us towards the desirable ends of accurate registration and efficient use. Since the /19 is the threshold number of sorts for flipping, I could accept a /20 as the maximum size. I think a 2 year wait is reasonable, but I don’t see the additional benefit as worth the distinction of ARIN space into more classes. And making it more complicated with multiple waiting periods is even less desirable, IMO. Regards, Mike From: ARIN-PPML <[email protected]<mailto:[email protected]>> On Behalf Of Fernando Frediani Sent: Wednesday, May 29, 2019 10:50 AM To: [email protected]<mailto:[email protected]> Subject: Re: [arin-ppml] Waiting List IPv4 blocks transferred after issuance On 29/05/2019 11:31, Mike Burns wrote: Orgs will wait out any period, sitting with unused addresses until they reach the resale date. Not efficient use. If it's not a legacy resource and if ARIN gets to know about it, it may just recover this addresses even if the resource holder is paying it correctly. That's how it should work. People will lease unused addresses to others and Whois accuracy will suffer if they can’t resell them. Not accurate registration. If people lease they prove they have no use for the addresses and again ARIN should recover them at any time. If whois is inaccurate, well it is their fault and not policies fault. They must bind to the current rules not the other way round. I think we should give everybody currently on the list up to a /19 and then restrict new entries to a /22. Fair to discuss this scenario, although I still think /19 is too much. Agree on /22 for new entries. I think a 5 year resale wait is too long, based on the paltry resales of prior waiting-list subnets smaller than /19. It may be long, but 2 years seems a little short and 'acceptable' for a fraudster. Perhaps something in between. I support a /22 restriction for new entrants, a /19 max for current list members, and maintenance of the 12 month wait for simplicity’s sake. What about discuss /22 for new entrants, /20 for current list members and 36, 42 or 48 months for transfers ? Seems more reasonable in my view and cover most aspects of this discussion. Regards, Mike From: ARIN-PPML <[email protected]><mailto:[email protected]> On Behalf Of Fernando Frediani Sent: Wednesday, May 29, 2019 8:51 AM To: [email protected]<mailto:[email protected]> Subject: Re: [arin-ppml] Waiting List IPv4 blocks transferred after issuance +1 On 28/05/2019 23:52, Owen DeLong wrote: Mike, Yes and no. I believe that the lack of legacy holders for any blocks issued under 4.1.8 reduces the need for the market. Defunct organizations can easily be reclaimed in this space because they stop paying their ARIN bill. Eliminating the resale value of these addresses won’t really encourage squatting on them and limiting the size of organization and size of block that can benefit from 4.1.8 further helps to reduce the potential for hoarding. I realize that as a broker, any address that can’t be monetized is a lost opportunity for your organization, but I think there’s plenty of addresses out there that haven’t been processed through 4.1.8, so I don’t think limiting the resale potential of such blocks to reduce fraud is a bad idea. Owen On May 28, 2019, at 12:46 , Mike Burns <[email protected]<mailto:[email protected]>> wrote: The percentages of blocks transferred takes a significant leap at the /19 size. Below that, the percentages are all below 7%. At /19 and above, the percentages are all above 21%. Seems like a natural demarcation for maximum block size, but prices do continue to rise. While we want to fight fraud, we should still remember the underlying reasons for the Ipv4 transfer market apply to these addresses as well. That is, the market provides incentives for efficient use and accurate registration. Regards, Mike From: ARIN-PPML <[email protected]<mailto:[email protected]>> On Behalf Of John Curran Sent: Tuesday, May 28, 2019 1:53 PM To: ARIN-PPML List <[email protected]<mailto:[email protected]>> Subject: [arin-ppml] Waiting List IPv4 blocks transferred after issuance Importance: High Folks - It occurred to me that it might be useful to have a quick summary of waiting list blocks issued and subsequently transferred. Attached is the distribution (count per prefix size) of all blocks that have been issued via ARIN's waiting list policy and subsequently transferred via NRPM 8.2/8.3/8.4 policy. FYI, /John John Curran President and CEO American Registry for Internet Numbers <image001.png> _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]<mailto:[email protected]>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected]<mailto:[email protected]> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]<mailto:[email protected]>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected]<mailto:[email protected]> if you experience any issues. _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]<mailto:[email protected]>). 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