Jordi -

The representation you seek from ARIN regarding government procedures across 
the the entire region is not possible to make – and as you note, it would be 
meaningless the very next day because such laws and regulations are outside of 
ARIN’s control and subject to change.  Note that this is the case regardless of 
whether speaking of networks run by organizations or individuals – the legal 
requirements on networks in any given portion of the ARIN region are not 
determined by ARIN.

What we can say is that our customers want us to be reasonably flexible in our 
processes to the extent possible, just as we are with respect to confirming 
whether organizations requesting resources operate within the ARIN region.  
We’ve evolved our processes over time to make be more straightforward, and this 
includes handling entities that are incorporated, those using DBA 
registrations, sole proprietorships, etc.

Your original query noted that ‘ In LACNIC we are having a discussion because 
the policy manual only allows to distribute resources to “organizations legally 
registered” ‘ – To be clear, ARIN is effectively the same, but we are quite 
flexible in recognition of how our network customers may go about their legal 
registration.

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers

On Apr 17, 2025, at 3:00 AM, jordi.palet--- via ARIN-PPML <[email protected]> 
wrote:

Hi John,

A couple of questions on this:

1) There is a formal confirmation that this “simple and “inexpensive” procedure 
is the same in all the “areas” (states, whatever is te division in each 
country) for all the service region countries of ARIN?

2) Are we sure that in all those areas/countries the cost of keeping that 
“status” (the one that is valid for ARIN), and I mean not only money, but also 
recurrent paperwork (like for example if you need to present quarterly/yearly 
tax reports, even if you don’t had economical activity), is close to “zero"?

3) As 1 and 2 above may change (a country law may decide that a 
sole-proprietorship may be enforced to something else much more expensive or 
cease that status), do it make sense that the policy and/or membership 
documents ask for something that doesn’t depend on ARIN decisions, instead of 
relaying in making sure that you provide “real documents” and of course a valid 
justification for the resources that you request (which is already set in the 
policies for each type of resource)?

Regards,
Jordi

@jordipalet


El 17 abr 2025, a las 2:34, John Curran <[email protected]> escribió:

Ryan -

Indeed.  As both myself (and Bill Herrin) have pointed out a few times in this 
discussion,  ARIN already has flexibility in this regard and we do have sole 
proprietorships that enter into agreements and obtain number resources.  Sole 
proprietorship works, DBA name registration works, incorporation of a legal 
entity works – hence the reason for further discussion in order to gain a 
better understanding of the problem to be solved.

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers


On Apr 16, 2025, at 8:16 PM, Ryan Hamel <[email protected]> wrote:

John,

I echo David's point coming from California. My ARIN resources are under my 
legal name, which was approved by the team that handles org tickets, and the 
legal team.

A sole proprietor without a DBA, can legally conduct business in several states 
and potentially provinces too, and that also includes signing ARIN's agreements.

Kind regards,

Ryan Hamel
________________________________
From: ARIN-PPML <[email protected]> on behalf of David Farmer via 
ARIN-PPML <[email protected]>
Sent: Wednesday, April 16, 2025 4:58:48 PM
To: John Curran <[email protected]>
Cc: arin-ppml <[email protected]>
Subject: Re: [arin-ppml] distributing resources for individuals

Caution: This is an external email and may be malicious. Please take care when 
clicking links or opening attachments.

John,

The issue is in Missouri, Minnesota, and probably many other states; if you are 
doing business under your own name and not a DBA, you don't need to register 
with the state to operate a sole proprietorship.

So, if ARIN procedures require a lookup with the Secretary of State, 
effectively, that requires more than just operating as a business; it also 
requires operating that business under a fictitious name, not under the owner's 
name.

Section 9 of the NRPM gives a lot of latitude for demonstrating that an 
organization operates within the ARIN region. A similar amount of latitude 
should be available to establish that an individual is acting as a business and 
not an individual, even if the jurisdiction's laws and procedures don't neatly 
align with ARIN procedures.

Thanks

On Wed, Apr 16, 2025 at 6:04 PM John Curran 
<[email protected]<mailto:[email protected]>> wrote:


On Apr 16, 2025, at 6:02 PM, Paul E McNary 
<[email protected]<mailto:[email protected]>> wrote:

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.

Paul -

To be certain there’s a clear understanding of the problem that resulted from 
the organization requirement – are you saying that you were unable to register 
a DBA name with Missouri Secretary of State in 2013?  There is a 7$ fee 
associated with such registration (every 5 years) but from all appearances it 
is otherwise a rather nominal process, so if there is/was some other barrier it 
would be good to explain it so that folks understand the scope of the problem 
that you experienced when trying to do so.

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers


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