The more I think about this proposal, the more disturbed I am by the following 
concept…

I do not think we should be building policy to facilitate the creation or 
expansion of “IPv4 landlords”. If an organization wishes to monetize its 
existing space through leasing rather than sale, I think this is a valid and 
perhaps even necessary service as mentioned in today’s meeting.

However, I do not want to see ARIN accepting “We’re acquiring more space in 
order to lease it out later” as a valid reason for approving a transfer into an 
organization. I think that legitimizing such transactions only creates 
additional incentives to distort the market.

As far as organizations which cannot afford IPv4 are concerned, I think that 
the general solution is a combination of IPv6 and NRPM 4.10.

Owen


> On Nov 1, 2019, at 7:28 AM, Owen DeLong <[email protected]> wrote:
> 
> I have trouble with both phrases.
> 
> Even if the resources are to be re-assigned to organizations or entities 
> which do not receive connectivity from the original registrant, I see no 
> reason to issue addresses to anyone who will not be using them on an 
> operational network.
> 
> Owen
> 
> 
>> On Oct 31, 2019, at 3:10 PM, Scott Leibrand <[email protected] 
>> <mailto:[email protected]>> wrote:
>> 
>> On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil <[email protected] 
>> <mailto:[email protected]>> wrote:
>> Dear All,
>> 
>> Prior to tomorrow's community discussion of Draft Policy ARIN-2019-18, I 
>> wanted to offer some clarification and propose some language for 
>> consideration to address questions posed on the PPML.
>> 
>> Regarding the question over the intended meaning of "non-connected 
>> networks", I will clarify that I mean this policy to refer to re-assignment 
>> to organizations and entities which do not receive connectivity from the 
>> original registrant.  
>> 
>> As such, I wanted to offer the following alternative edit to 8.5.2: 
>> 
>> 8.5.2 Operational Use
>> ARIN allocates or assigns number resources to organizations via transfer 
>> primarily for the purpose of use on an operational network, but may allocate 
>> or assign number resources to organizations for other purposes, including 
>> re-assignment to organizations and entities which do not receive 
>> connectivity from the original registrant.
>> 
>> 
>> I believe this is consistent with the intent of 2019-18, and I would support 
>> this language.
>>  
>> 
>> 
>> Alternatively, and more simply, since the sentence referencing 
>> "non-connected networks" starts with "including" and is therefore not meant 
>> to be an exclusive "other purpose", but rather illustrative, we can remove 
>> it entirely.  That option would read: 
>> 
>> 8.5.2 Operational Use
>> ARIN allocates or assigns number resources to organizations via transfer 
>> primarily for the purpose of use on an operational network, but may allocate 
>> or assign number resources to organizations for other purposes.  
>> 
>> I believe this is materially different than the text above, in that it would 
>> give ARIN permission to approve transfers for any reason whatsoever. ARIN in 
>> the past has interpreted such ambiguity in favor of allowing whatever is not 
>> expressly prohibited. As such, I don't think this language accomplishes the 
>> original intent, and would oppose it.
>> 
>> -Scott
>>  
>> *please note that the online version of the policy proposal reads "solely 
>> primarily" instead of "primarily".  This is a typo due to originally 
>> proposing the language with the word "solely" in strike-through text 
>> (solely), which did not translate.  
>> 
>> Further, I want to clarify, as the original author of the proposal, that the 
>> key intent of the policy is to acknowledge that small and medium-sized 
>> businesses have a need for IPv4 space, but often cannot afford to buy space 
>> in the current market.  Legitimizing a subleasing market increases 
>> accessibility to IPv4 space, and opens the market to business solutions to 
>> facilitate safe, trusted subleasing practices, including keeping the correct 
>> registry updated.  
>> 
>> Thanks all for the continued discussion.  
>> 
>> Best,
>> 
>> Kiran
>> -- 
>> Kiran Malancharuvil
>> Open-i Advisors      
>> p:  415 419 9138
>> http://openiadvisors.com 
>> <http://openiadvisors.com/>_______________________________________________
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