Hi,

I would like to express my opinion on this policy. As a broker it's
obviously in my interest to shorten the supply in order to increase the
prices as my commission is directly related to the price. And probably
that's what every IPv4 address broker would hope for.

As a community member I would just analyze the data. And the fact is
that since the first transfer in october 2012 until now there were a
total of 273.408 IPs transferred from 185.0.0.0/8 which represents 1.83%
from the total 14.895.616 IPs transferred.

Below is the monthly table for theese transfers:
+---------+------+
| month   | /22s |
+---------+------+
| 2013-01 |    1 |
| 2013-05 |    1 |
| 2013-07 |    3 |
| 2013-10 |    1 |
| 2013-12 |    1 |
| 2014-01 |    5 |
| 2014-02 |    9 |
| 2014-03 |    3 |
| 2014-04 |    2 |
| 2014-05 |    6 |
| 2014-06 |    7 |
| 2014-07 |    6 |
| 2014-08 |    6 |
| 2014-09 |   15 |
| 2014-10 |   15 |
| 2014-11 |   17 |
| 2014-12 |   38 |
| 2015-01 |   21 |
| 2015-02 |   19 |
| 2015-03 |   25 |
| 2015-04 |   39 |
| 2015-05 |   19 |
| 2015-06 |    9 |
+---------+------+

I can't see an exponential growth or a threat to the last /8 available
pool. Actually as you know the pool has increased over the 2.5 years
instead of being depleted.

One other problem would be the name of the policy. Alignment of Transfer
Requirements. It's actually a chage of transfer requirements. There were
other IPs that were sold less than 2 years from the date they were
obtained and that was a real problem.

I will take a single example: 5.186.0.0/16. It was allocated by RIPE on
08.08.2012, during the last-mile fight for IPs and they were allocated
to a natural person, which I don't suppose was running such a big
business at that time to justify the real need. Then the IPs were sold
on 02.07.2014. I remember it was very difficult for me to get a /14 for
the biggest ISP in Romania in april 2012. How difficult was for others
to get /16s, /15s, /14s which now are already sold ?

How many IPs from the 5.0.0.0/8 (the pre-last one) were already sold ?
1.783.808. In my opinion theese are the IPs that were taken for free and
only to be sold by "smart guys". Maybe there were some bribes involved
but all the money went to the right pockets.

How can any sane person compare such an abuse with the "abuse" that is
happening today on the last /8 ? Obviously some people are making profit
taking advantage of this but an important amount of the money goes back,
as someone noted, to the community. So in this case there is a flaw that
is exploited and it's results are : lower membership fees, quicker IPv4
depletion, more supply to the market helping temper the prices. Theese
are the effects and I think any community member would agree that theese
are all positive.

If you want to analyze and do some corrections look to the abuses done
in the past and find the persons that were part in that activity.

We have a saying in Romania, "the country burns and the old lady brushes
her hair".

A plus from me to the fellow brokers that fight with all means to keep
the market prices high, as I'll make more money too.

A big minus from me to this policy as I think that profit should not be
the only reason that drives our actions.

Ciprian Nica
IP Broker Limited

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