Preston,
Do you have suggestion about what barrier that needs to be removed?
While filing for a DBA or registering as a business is a step, to me it
seems like a very small step and in many cases a much smaller step than
applying to ARIN for number resources. For example, in the state of
Washington, one can file online for about $55 and the process would
probably take less than 10 minutes.
Andrew
On 4/16/2025 1:09 PM, Preston Ursini via ARIN-PPML wrote:
Remove the barrier for legitimate networks operated by individuals,
the door shouldn’t be open for anyone, it needs to remain in place for
legitimate network operators that can justify the needs for the
assets, whether they be for an individual or corporation.
The other requirements for numbering assets should otherwise remain
the same in relation to this proposed policy change, and validated
proof of identification of the individual should also be recorded in
some way.
Looking further back at the issue, it is likely easier for people
committing fraud to incorporate fake companies through state level
secretary of state offices and work under the name of a fake company
versus working under the name of a fake individual. So validating the
identity of an individual, whether the application be for a company or
individual, is probably a good idea all around. Name / Date of Birth
/ Government Issued Identify Document at a minimum.
Preston Ursini
On Apr 16, 2025, at 3:02 PM, John Curran <[email protected]> wrote:
Preston -
As a point of clarity – when you suggest that “removing this barrier
should be given great consideration”, do you mean for removing the
barrier for "legitimate networks operated by individuals” (such as
you referenced in your explanation), or for removal of the barrier
for individuals in general?
Thanks,
/John
John Curran
President and CEO
American Registry for Internet Numbers
On Apr 16, 2025, at 3:51 PM, Preston Ursini via ARIN-PPML
<[email protected]> wrote:
I know of at least one individual that was working to start a
network and was harmed by this. He is a colocation customer,
unincorporated, and uses his network for himself and his place of
employment; however the employer did not want to go through the
process of obtaining numbering assets from ARIN, and the network is
used for his own joint venture. He simply saw the requirement and
did not proceed.
I would ascertain that most legitimate networks operated by
individuals is probably relatively small, however our colo somewhat
acts as a network incubator giving a place for small networks to
grow. I believe most individuals stopped by this requirement would
not reach out to ARIN for change. If you look at some IXPs you’ll
see there are plenty ran under assumed names, with some IXPs
themselves being ran by individuals that aren’t incorporated.
If you look into small ISPs and IXPs, and their start, you’ll find
that many of them start off as unincorporated sole proprietors. One
thing we’ve found is that these networks are likely to end up
leasing IP space from an upstream provider as the barrier to
obtaining their own IP Assets may be seen as too high. In short,
this causes providers that could probably get away with IPv6 + NRPM
4.10 IPv4 w/ CG-NAT are being forced to lease IPv4 as these lessors
have a financial incentive to show leased IPv4 as a necessity for a
new network, thus also possibly having the effect of stalling IPv6
adoption for these small networks that in turn grow into large ones.
Getting them onboarded w/ ARIN and running IPv6 from the start
would be a win. More educational material for IPv6 and numbering
planning from ARIN would be great, and lowering and/or removing
perceived barriers to entry will do a lot long term to help with this.
In short: We help small networks navigate this, and we have seen the
requirement for a business license / assumed name / etc act as a
barrier to entry for small networks, and I believe even for small
IXPs, and may have a side effect of causing a barrier to IPv6
adoption for small networks.
I believe the notion of removing this barrier should be given great
consideration.
Preston Ursini
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