Originally 12 years ago when I tried to get ARIN resources, I was greatly harmed by this. In Missouri at that time a Sole Proprietor did not have to register with the Secretary of State. ARIN would not issue resources unless they could verify you with Secretary of State database. We had a State Sales Tax and Employment Tax ID for 20 years, but that wasn't good enough. 3-4 years later the Secretary of State would allow us to request a fictitious name which couldn't match our legal name and individual. That still wasn't good enough for ARIN. 2 years later we setup an LLC and got an ASN number to move between upstream bandwidth suppliers but IPv4 was now gone. Our upstream supplier clawed back a /22 and /23 which caused great harm because we couldn't replace them. So yes ARIN CAUSED GREAT HARM in not accepting our state resale number as proof of business as a sole proprietor. Secretary of State still doesn't require registration in Missouri if you have a state Tax ID through Department of Revenue. And now in our LLC which ARIN would use. An LLC of 1 member, the Missouri Department of Revenue says must have at a minimum of 2 members even though the Secretary of State says an LLC of 1 is OK. So about 5 years of great harm.
From: "Andrew Dul via ARIN-PPML" <[email protected]> To: "arin-ppml" <[email protected]> Sent: Wednesday, April 16, 2025 3:55:48 PM Subject: Re: [arin-ppml] distributing resources for individuals 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 BQ_BEGIN On Apr 16, 2025, at 3:02 PM, John Curran [ mailto:[email protected] | <[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 BQ_BEGIN On Apr 16, 2025, at 3:51 PM, Preston Ursini via ARIN-PPML [ mailto:[email protected] | <[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 BQ_END _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ( [ mailto:[email protected] | [email protected] ] ). Unsubscribe or manage your mailing list subscription at: [ https://lists.arin.net/mailman/listinfo/arin-ppml | https://lists.arin.net/mailman/listinfo/arin-ppml ] Please contact [ mailto:[email protected] | [email protected] ] if you experience any issues. BQ_END _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
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