On Tue, Jul 26, 2022 at 9:46 AM Michael Peddemors <[email protected]> wrote:
> Noticing more cases of IP Assignments for a 'company' with a North > American presence, that simply reassigns/reallocates portions of their > IP assignments to offshore and foreign companies with no North American > presence at all.. > > How does the intent of ARIN guidelines apply, when a 'shell' company is > formed to provide IP ranges for companies outside of the ARIN region? > > Just curious.. > I'm not a lawyer, I'm not an ARIN staff member, so take everything I write with less than a grain of salt--but with that said: I think it's important to understand that ARIN requirements generally aren't transitive. That is, a requirement in the NRPM that the entity requesting number resources have "a real and substantial connection with the ARIN region" does not in any way require the *customers* of that entity also have a real and substantial connection with the ARIN region. If I form a company, 'X', and build a network predominantly in the ARIN region, fulfilling the requirement that 'X' has "a real and substantial connection with the ARIN region", and get number resources based on that; but all of my customers end up being mostly outside the region, connecting to one of my edge sites outside the ARIN region, no fraud has been perpetrated, because the letter of the NRPM has been met. Now, if the initial company is a "shell" company in the literal sense, in that it has nothing more than a corporate PO box in the ARIN region, and no tangible assets (no routers, no network, no servers, etc.), then yes, there's a case to be made that fraud has been perpetrated. However, if the original company *does* have a network within the ARIN region, and appropriately justified its number resources based on that infrastructure, even if all of their subsequent customers lie outside the region, according to the current wording of the NRPM, no fraud has occurred. You could try proposing a change to the NRPM that would require ARIN member entities to ensure all their downstream customers *also* have "a real and substantial connection with the ARIN region", but I doubt you'll find much support for that, as it would greatly increase the up-front cost of vetting customers with no corresponding increase in revenue to support it. Thanks! Matt
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