Is a VPS company an ISP or an end user?

ARIN told me in a ticket regarding an initial IPv4 end-user request
(this is yesterday) that the virtual server (VPS) company i work for,
is NOT an end-user, but is an ISP.  Each virtual servers uses less
than a /29, and we do not do SWIP, reallocate, or reassign any IP
space.  The company only provides virtual servers.



On Wed, Jul 17, 2013 at 2:18 PM, Owen DeLong <[email protected]> wrote:
>
> On Jul 17, 2013, at 4:34 PM, William Herrin <[email protected]> wrote:
>
>> On Wed, Jul 17, 2013 at 4:02 PM, Justin Krejci <[email protected]> 
>> wrote:
>>> Here is my newbie and possibly naive response.
>>>
>>> Without additional details on individual cases in the list, I would expect 
>>> all of those cases to be "end-users" as none of them are in the business of 
>>> reallocating address blocks. Right or wrong I've always been under the 
>>> impression this to be the general rule of thumb: if allowed to reallocate 
>>> then you're an ISP, else end-user; maybe to back up even further the 
>>> primary purpose of the listed organizations are not to provide Internet 
>>> connectivity services nor is it their primary goal or likely even a 
>>> secondary goal.
>>>
>>> Akamai, provide effective access to 3rd party content
>>> Google, provide advertising, searching, and various web related services
>>> U of Maryland, provide education
>>> Starbucks, provide beverages and calories in solid form
>>> Hilton/Marriott, provide hospitality
>>> Linode, provide virtual server hosting
>>> Godaddy, provide DNS/web hosting
>>>
>>> In any case, NRPM 2.6 says, "An end-user is an organization receiving
>>> assignments of IP addresses exclusively for use in its operational
>>> networks." I think all of these example cases seem to fit this wording
>>> as they are operating their identified systems within their operational
>>> networks.
>>
>> Hi Justin,
>>
>> What about Verizon Wireless? They're primarily a cellular phone
>> company, and the overwhelming majority of the phones on which IP
>> addresses are used are still on the rent-to-own plan where you have to
>> complete the 2 year contract before you actually own the phone. Untill
>> then you're just leasing the use of their equipment.
>
> It's my understanding that it is inappropriate to name particular companies 
> in this case, but the below applies equally well to $CELLCO, so I'll speak to 
> that.
>
> That's not true. If you were leasing their equipment, then you could 
> terminate the contract and give the equipment back to them. Instead, you have 
> to reimburse them for the subsidy (and possibly more in most cases). You 
> bought the phone at a reduced price. You agreed to a service contract in 
> exchange for that reduced price. If you terminate the contract early, you are 
> obliged to pay back said discount.  That is to the same as leasing equipment 
> they own.
>
>> ISP or end-user?
>
> ISP… $CELLCO generally assigns a block of addresses to the phone (at least my 
> $CELLCO assigns a /64 to my phone) and should be registering those 
> assignments. Further, they are also providing a service which is intended to 
> provide internet access to customer-owned hardware (your lease argument 
> doesn't actually hold water as stated above). Even if the hardware is leased, 
> it still counts as hardware under the customer's control.
>
>> What about Comcast? They're in the business of providing cable
>> television service. They'll also provide you with Internet access on
>> the same coax cable with the modem they rent you.
>>
>> ISP or end-user?
>
> The service is intended to be used to connect customer-owned equipment to the 
> internet. As such, they are clearly in the LIR/ISP realm.
>
> Owen
>
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