In my view, Secretary of State (SOS) registration is an easy button for ARIN, and when available, that's fine. Nevertheless, I also expect ARIN to have processes and procedures in place when the SOS option is not available. A sole proprietorship that is not registered with the SOS is still a valid business in many states, and ARIN needs processes and procedures in place to deal with that situation.
Earlier, I referenced Section 9 and the flexibility in determining that an organization is operating in the ARIN; similar flexibility is needed in determining whether an individual is operating as a business. I'll also note that Section 9 is quite clear: registration in the ARIN region alone is not sufficient to determine whether an organization is operating in the ARIN region. Similarly, a lack of registration alone should not be sufficient to find that an individual is not operating as a business. As to ARIN policy, it predominantly references organizations. Individuals only come up in the context of defining a Residential Customer. With that context, ARIN policy strongly assumes LIRs, ISPs, and end-users are organizations, not individuals. Thanks. On Fri, Apr 18, 2025 at 11:05 AM Owen DeLong <[email protected]> wrote: > Not all states will register a sole proprietorship under a person’s legal > name, making it difficult for some sole proprietorships to clear ARIN’s > current requirements. Worse, individuals and sole proprietors who know > which buttons to push on the ARIN staff seem to be able to get ORG-IDs > without SOS registration while others seem to get rejected on that basis. > > I’m not arguing that these “exceptions” should go away, I’m arguing that > they should be more widely available and perhaps it is time to drop the > “organization” pretext altogether. > > Owen > > > On Apr 17, 2025, at 17:54, David Farmer via ARIN-PPML <[email protected]> > wrote: > > > Ok, natural persons can be RIPE members in their own right, I guess I was > wrong, but you pay €1,800 for membership. Where as with ARIN you start at > $250, even with potential state registration fees for a sole > proprietorship, you probably still come out well ahead. > > On Thu, Apr 17, 2025 at 19:43 David Farmer <[email protected]> wrote: > >> Out of curiosity can you point me to the agreement on RIPE’s web site. >> >> Thanks >> >> On Thu, Apr 17, 2025 at 19:38 Ryan Hamel <[email protected]> wrote: >> >>> David, >>> >>> I signed an agreement with RIPE NCC, have an account in their portal, >>> and had an ASN + IPv6 assignment... >>> >>> Kind regards, >>> >>> Ryan Hamel >>> ------------------------------ >>> *From:* ARIN-PPML <[email protected]> on behalf of David >>> Farmer via ARIN-PPML <[email protected]> >>> *Sent:* Thursday, April 17, 2025 6:35:37 PM >>> *To:* John Curran <[email protected]> >>> *Cc:* Preston Ursini <[email protected]>; [email protected] < >>> [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. >>> >>> First, my understanding is that individuals don't get resources from >>> RIPE either; Member Organizations do. You, as an individual, get >>> resources from an LIR that is a RIPE Member, and the LIR gets the >>> resources from RIPE, maintains the relationship with RIPE, and assigns >>> them to you. As an individual, your relationship is with the LIR, not RIPE, >>> unless I'm completely misunderstanding RIPE's policies and business >>> practices. >>> >>> A similar arrangement could be facilitated by an LIR (also known as an >>> ISP) that is an ARIN Member Organization. That isn't as common a practice >>> here in the ARIN Region. ARIN has a lower barrier to entry and deals >>> directly with end-user organizations, but not end-users as individuals. >>> >>> Thanks. >>> >>> On Thu, Apr 17, 2025 at 6:51 PM John Curran <[email protected]> wrote: >>> >>> Preston - >>> >>> I don’t think any of the present discussion has been predicated on fraud >>> concerns. >>> >>> (Note that ARIN currently has some extensive anti-fraud practices that >>> include various forms of government issued ID presentation and >>> verification.) >>> >>> Thanks, >>> /John >>> >>> John Curran >>> President and CEO >>> American Registry for Internet Numbers >>> >>> >>> On Apr 17, 2025, at 7:39 PM, Preston Ursini <[email protected]> >>> wrote: >>> >>> Would I be correct in that there hasn’t been an actually policy proposal >>> submitted for this? >>> >>> I believe that whether or not this new policy were to be considered, >>> that a copy of a government issued identification document be submitted to >>> the person signing the Registration Services Agreement whenever an OrgID is >>> issued. This can help immensely in tracking down fraud which seems to be a >>> pillar concern. >>> >>> For simplicity sake, I’d also say in any such policy allowing an >>> Individual to obtain numbering assets simply be issued an OrgID just as >>> sole proprietors are as to minimize disruption to ARIN operations in >>> implementing this policy. >>> >>> >>> Preston Ursini >>> >>> >>> On Apr 17, 2025, at 6:28 PM, John Curran <[email protected]> wrote: >>> >>> Preston - >>> >>> That’s a reasonable question (“why an individual cannot be accepted as >>> they are generally the same legal entity…”) >>> >>> You’re right that a sole proprietorship is legally tied to the >>> individual behind it, but that doesn’t make it the same as issuing >>> resources to individuals. At the time of ARIN’s formation (and for a >>> suibstantial period before), number resources were issued to organizations. >>> The old netnumber.txt request forms made that clear, asking for “the >>> organization responsible for establishing the network” along with a postal >>> address. That model is what ARIN inherited when it was formed in 1997, and >>> it’s what we continue to operate under. >>> >>> While it’s true in theory that ARIN could adopt a model where it >>> directly serves individuals, this would represent a significant departure >>> from the registry model we inherited and have operated under for decades. >>> Even though individuals and organizations can both be “legal entities,” >>> that does not mean they are treated identically under law. For example, >>> companies that predominantly focus on serving businesses (often referred to >>> as B2B) are often subject to different laws, regulations, and tax policy >>> than those that hold themselves out to serve individuals. Thus, shifting to >>> a model that openly includes individuals could have significant unintended >>> implications for ARIN. >>> >>> That doesn’t mean it can’t be done, but it would be important to >>> understand the problem that such a change would solve. ARIN accepts >>> incorporated entities, DBAs, sole proprietors, etc.—because we know >>> networks are run by all kinds of operators. But in every case, we’re still >>> issuing to an organization, however minimal the structure might be. >>> >>> Thanks! >>> /John >>> >>> John Curran >>> President and CEO >>> American Registry for Internet Numbers >>> >>> On Apr 17, 2025, at 2:09 PM, Preston Ursini via ARIN-PPML < >>> [email protected]> wrote: >>> >>> If a sole proprietorship is accepted, I am confused as to why an >>> Individual cannot be accepted as they are generally the same legal entity >>> unless it is an individual? >>> >>> There are over 20,000 political subdivisions within the United States >>> when you count cities, counties, townships, etc., all with their own rules >>> when it comes to business licenses and conducting business, trying to tie >>> every sole proprietorship down with a business license when one may not be >>> required in many of these jurisdictions seems strange at best. >>> >>> In general the law sees Corporations and Individuals as all in the same, >>> so I’m a little confused as to why ARIN would be ok with doing business >>> with a sole proprietor but not an "individual"? >>> >>> If the issue is fraud prevention, it seems like a better approach would >>> be tying all accounts regardless of whether it is a business/individual, >>> with a government issued identification document; the trend with having an >>> officer of a company sign an RSA seems to be a step in the direction in >>> tying real people to accounts; assuming the goal here is to ensure >>> accountability for resource allocation? >>> >>> >>> >>> Preston Ursini >>> >>> >>> On Apr 17, 2025, at 7:21 AM, [email protected] wrote: >>> >>> Send ARIN-PPML mailing list submissions to >>> [email protected] >>> >>> To subscribe or unsubscribe via the World Wide Web, visit >>> https://lists.arin.net/mailman/listinfo/arin-ppml >>> or, via email, send a message with subject or body 'help' to >>> [email protected] >>> >>> You can reach the person managing the list at >>> [email protected] >>> >>> When replying, please edit your Subject line so it is more specific >>> than "Re: Contents of ARIN-PPML digest..." >>> >>> >>> Today's Topics: >>> >>> 1. Re: distributing resources for individuals >>> ([email protected]) >>> 2. Re: distributing resources for individuals (John Curran) >>> >>> >>> ---------------------------------------------------------------------- >>> >>> Message: 1 >>> Date: Thu, 17 Apr 2025 09:00:26 +0200 >>> From: "[email protected]" <[email protected]> >>> To: arin-ppml <[email protected]> >>> Subject: Re: [arin-ppml] distributing resources for individuals >>> Message-ID: <[email protected]> >>> Content-Type: text/plain; charset="utf-8" >>> >>> 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]> escribi?: >>> >>> 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 >>> >>> >>> _______________________________________________ >>> 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. >>> >>> >>> >>> >>> ********************************************** >>> IPv4 is over >>> Are you ready for the new Internet ? >>> http://www.theipv6company.com >>> The IPv6 Company >>> >>> This electronic message contains information which may be privileged or >>> confidential. The information is intended to be for the exclusive use of >>> the individual(s) named above and further non-explicilty authorized >>> disclosure, copying, distribution or use of the contents of this >>> information, even if partially, including attached files, is strictly >>> prohibited and will be considered a criminal offense. If you are not the >>> intended recipient be aware that any disclosure, copying, distribution or >>> use of the contents of this information, even if partially, including >>> attached files, is strictly prohibited, will be considered a criminal >>> offense, so you must reply to the original sender to inform about this >>> communication and delete it. >>> >>> -------------- next part -------------- >>> An HTML attachment was scrubbed... >>> URL: < >>> https://lists.arin.net/pipermail/arin-ppml/attachments/20250417/59eecf73/attachment-0001.htm >>> > >>> >>> ------------------------------ >>> >>> Message: 2 >>> Date: Thu, 17 Apr 2025 12:21:30 +0000 >>> From: John Curran <[email protected]> >>> To: "[email protected]" <[email protected]> >>> Cc: arin-ppml <[email protected]> >>> Subject: Re: [arin-ppml] distributing resources for individuals >>> Message-ID: <[email protected]> >>> Content-Type: text/plain; charset="utf-8" >>> >>> 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]> escribi?: >>> >>> 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 >>> >>> >>> _______________________________________________ >>> 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. >>> >>> >>> ********************************************** >>> IPv4 is over >>> Are you ready for the new Internet ? >>> http://www.theipv6company.com >>> The IPv6 Company >>> >>> This electronic message contains information which may be privileged or >>> confidential. The information is intended to be for the exclusive use of >>> the individual(s) named above and further non-explicilty authorized >>> disclosure, copying, distribution or use of the contents of this >>> information, even if partially, including attached files, is strictly >>> prohibited and will be considered a criminal offense. If you are not the >>> intended recipient be aware that any disclosure, copying, distribution or >>> use of the contents of this information, even if partially, including >>> attached files, is strictly prohibited, will be considered a criminal >>> offense, so you must reply to the original sender to inform about this >>> communication and delete it. >>> >>> _______________________________________________ >>> 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. >>> >>> -------------- next part -------------- >>> An HTML attachment was scrubbed... >>> URL: < >>> https://lists.arin.net/pipermail/arin-ppml/attachments/20250417/4718a46d/attachment.htm >>> > >>> >>> ------------------------------ >>> >>> Subject: Digest Footer >>> >>> _______________________________________________ >>> ARIN-PPML mailing list >>> [email protected] >>> https://lists.arin.net/mailman/listinfo/arin-ppml >>> >>> >>> ------------------------------ >>> >>> End of ARIN-PPML Digest, Vol 238, Issue 17 >>> ****************************************** >>> >>> >>> _______________________________________________ >>> 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. >>> >>> >>> >>> >>> _______________________________________________ >>> 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. >>> >>> >>> >>> >>> -- >>> =============================================== >>> David Farmer Email:[email protected] >>> Networking & Telecommunication Services >>> Office of Information Technology >>> University of Minnesota >>> 2218 University Ave SE >>> <https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g> >>> Phone: 612-626-0815 >>> Minneapolis, MN 55414-3029 Cell: 612-812-9952 >>> =============================================== >>> >> _______________________________________________ > 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. > > -- =============================================== David Farmer Email:[email protected] Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 ===============================================
_______________________________________________ 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.
