Hello Denis,
Thank you for your questions. Allow me to answer as many as I can right
now. As you indicated, getting the data for some of the requests in your
email from 9 December would require quite some time and effort.
Considering that Registry Services is currently in the busiest time of
the year, I would prefer to first identify if this data would really be
beneficial for the ongoing discussion about the IPv4 waiting list policy
and potential policy proposal.
For example, you asked if some members with 10+ LIR accounts are brokers
or are from a certain country. What I can say is that these members are
quite diverse. They are located in several countries inside and outside
of our service region.
Some of these 98 organisations only became members in the last two
years, while others opened multiple LIR accounts in the past several
years and so received multiple /22 IPv4 allocations under the former
"Last /8” policy, and later /24 IPv4 allocations under the current
policy. Those members received around 1,100 /22s between September 2012
and November 2019, when the "Last /8" policy was in place.
As for your comments about consolidations, I would like to clarify that
the RIPE NCC uses this term when a member consolidates some of their LIR
accounts into another LIR account. When an LIR receives resources that
are restricted by a holding period, those resources must be kept in that
LIR account until the holding period has passed. After that 24-month
period, these members usually decide to consolidate their LIR accounts,
including their resources. If a company were to take over one of its
child companies, this would be processed by the RIPE NCC as a merger of
two different legal bodies.
To provide some more numbers, besides the 98 members that hold 10 or
more accounts, we currently have 112 members that hold between 5 and 9
LIR accounts.
The maximum amount of /24 allocations that a single member has received
under the current policy is 33.
So far, no allocations received under the current waiting list policy
have been transferred due to the fact that the first such allocation was
provided around 24 months ago and almost all allocations are still
within their holding period.
I hope this answers most of your questions.
Kind regards,
Marco Schmidt
Assistant Manager Registry Services
RIPE NCC
On 14/12/2021 14:20, denis walker wrote:
Hi Guys
I have some more questions now as I dig deeper into these allocations.
Marco mentioned in his email that the situation is quite fluid because
of consolidations, transfers, and opening of new LIR accounts that
occur all the time. I have found the transfer information, where can I
find details of consolidations? Also is the waiting list published
anywhere? I have seen companies with say 25 LIRs where 22 have already
received a /24 this year. I would like to know if the other 3 LIRs are
on the waiting list and at what position.
Now I have some detailed questions about what is meant by
consolidation. I will illustrate with an anonymous example. For all my
analysis I will not identify any company by name. My intention is to
expose behaviour.
So we have a parent company ABC Networks BV. They set up 5 child
companies. One in 2017 and 4 in early 2019. One of them is XYZ
Networks BV.
XYZ networks BV opens 12 LIRs. Throughout 2019 each of these LIRs
receive a /22 allocation. In December 2019 all these LIRs/allocations
moved to the parent company ABC Networks BV and the child company XYZ
Networks BV was deregistered according to the Chamber of Commerce.
In total the 5 child companies opened 50 LIRs. They each received a
/22 throughout 2019 and all these child companies were deregistered in
December 2019 with their LIRs/allocations 'transferred' to the parent
company. Is this what is meant by consolidation? Not sure what the
business case is to register several companies who open several LIRs
each to get allocations, then close the companies a few months later
and merge all the resources into the parent company...unless it is to
try to hide the true number of LIRs the parent company has set up.
The timing is also interesting. All of these child companies were
merged with the parent company on 2 December 2019, according to the
Chamber of Commerce:
"Merger deed passed on 02-12-2019. Acquiring legal entity: ABC
Networks BV Disappearing legal entities: XYZ Networks BV..."
The child companies were then all deregistered on 5 December 2019,
according to the Chamber of Commerce:
"As of 5-12-2019, the legal entity has been deregistered due to
Termination of registration"
According to the Transfer Statistics the date of the transfer of the
resources was 23 December 2019 from the child company XYZ Networks BV
to the parent company ABC Networks BV. The ORGANISATION objects in the
RIPE Database were also modified on 23 December 2019 to change the
"org-name:" to that of the parent company ABC Networks BV. But the
child company XYZ Networks BV did not exist on 23 December 2019. So
was this a valid transfer? This applies to all 50 of the allocated
resources to these child companies's LIRs.
I suspect that when the merger took place on 2 December 2019 the
parent company took legal ownership of the assets of the child
company, including the LIR accounts with the allocated resources. That
means the transfer actually took place on 2 December 2019, not the 23
December 2019 as stated in the Transfer Statistics. That makes the
Transfer Statistics wrong. If this is meant to be a legal document
that is not good. Something needs to be tightened up here. Maybe it is
a chicken & egg situation. The merger has to legally occur and
documents supplied to the RIPE NCC before the transfer can be
acknowledged. But then the transfer stats should make it clear the
transfer actually took place on 2 December when the merger occurred,
not the date it was acknowledged by the RIE NCC on 23 December.
It is also not clear to me what has actually been
transferred/acquired? Is it the allocations or the LIR accounts with
the allocations? In the delegated stats there still exists several
entries for nl.xyz1, nl.xyz2, etc. These all refer to the legal name
of the parent company ABC Networks BV. Does this mean the parent
company has taken control (acquired) all 50 of these LIR accounts with
their allocations, not just the allocations? Is this still a
consolidation?
Another general question. When a whole resource is transferred (within
RIPE region) it looks like the RIPE NCC deletes and recreates the
allocation object in the RIPE Database with 'todays' date as the
creation date. But the entry in the delegated stats keeps the original
allocation date. Is this how it is meant to be documented? (A good
example of why a historical query in the RIPE Database should show the
full history.)
None of this is explained very well, or at all, in the policies or
documentation. It assumes people know a lot more about this
registration stuff than a database expert does (but I am learning). If
someone can answer these points it may well help some of the new LIRs
as well. I am sure there is a steep learning curve here for the newbies.
cheers
denis
co-chair DB-WG
On Mon, 13 Dec 2021 at 17:17, Albanian Hosting SH.P.K. via
address-policy-wg <[email protected]> wrote:
Hey Denis Walker,
in 2019 until the end of december the last /22 allocation was
assigned to the members/Lirs, once the ripe stopped assigning /22,
there was not that much interest in 2020 for only a /24 subnet.
And no, it was not free! Since in 2021 the price per
IP skyrocketed, and ripe announced that they are out of stock, due
because of this and due because the price per IP is going to the
moon, the LIRs (mostly big boys) with multiple allocations started
to apply for more and believe me they are making a good profit
from this. For now is 200€/month is the price for /24 subnet to
rent out, and it will be higher and higher.
Cheers.
--
*Sinqerisht / Sincerely,*
AlbHost Logo <https://www.albahost.net/>
Albanian Hosting SH.P.K.
Besim Beka p.n.
50000 Gjakovë, Kosovë.
NIPT/VAT ID: 811442657
T: +386900501502
E: [email protected]
W*: *wWw.AlbaHost.Net <http://www.albahost.net/> Facebook icon
<https://www.facebook.com/albanianhosting> Twitter icon
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<https://www.instagram.com/albahost_vpn/>
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