Hi Owen,
2014-14 calls for a /16 limit.
You expect some organization to advertise they will buy a /16, and then just
change names and prosecute a series of transactions, each requiring a new
ORG-ID. You know, there are a growing group of people who are striving every
day to advertise the same thing. Brokers like me. We have to balance the
advertising costs with the deal profits. There is no secret place where you
can place an ad and magically find enough /16 sellers to change this market.
And have sellers be serially faked into believing they are talking to
separately spun-up organizations. And these organizations, though legally
separate, are shells which are to collude under the control of some existing
entity with billions of dollars to spend? An entity who is not afraid of
driving us faster towards IPv6 and a zero value to IPv4? I deal with ARIN
quite a bit, and I don't for one minute believe that they could start seeing
ORG-IDS spun up, and then each receiving a needs-free transfer, repeated
thousands of times, and fail to notice it. Nor do I believe it could
conceivably happen in any sudden timeframe. In fact, the whole idea is just
inconceivable.
Call me naive, but I would just speculate in RIPE. Maybe pick up some of
those multiple /8s gathering dust? Save the creation of about 512 new dummy
puppet corporations for /16s?
But wait, the evidence in RIPE, after dropping the needs-test, and the short
experience in APNIC, when they dropped the needs-test, does not support your
speculation speculation.
From the ARIN staff review of 2014-14:
Exceptions to needs based review can be justified because the
smaller size of the blocs does not provide a significant vehicle
to 'game', 'hoard', or 'speculate' sizable IP resource blocks of size. Owen:
Want to bet that there are not organizations out there that would be able to
create enough entities to absorbe 4,000 /16s pretty quickly for the sake of
attempting to flip them at a speculative profit?Mike: I would absolutely
take your bet.Owen: Unfortunately, since this is a case where what would be
bet is the best interests of the community, the stakes aren't mine to wager,
nor are they yours.Mike: My bad?Regards,Mike
----- Original Message -----
From: "Owen DeLong" <o...@delong.com>
To: "Mike Burns" <m...@iptrading.com>
Cc: "Randy Carpenter" <rcar...@network1.net>; "Steven Ryerse"
<srye...@eclipse-networks.com>; <arin-ppml@arin.net>
Sent: Saturday, December 20, 2014 6:19 PM
Subject: Re: [arin-ppml] Internet Fairness
On Dec 20, 2014, at 10:45 , Mike Burns <m...@iptrading.com> wrote:
It's utterly simple to create artificial entities, if necessary.
There are only about 48,000 /16s en toto in all of the IPv4 unicast space.
In reality, when you consider the potential transfer market, it's more
likely on the order of 4,000.
Want to bet that there are not organizations out there that would be able
to create enough entities to absorbe 4,000 /16s pretty quickly for the
sake of attempting to flip them at a speculative profit?
I think it's a bad bet.
Owen
Hi Owen,
That old chestnut again. So little faith in ARIN staff members to detect
what would have to be monumental levels of fraud before any market
manipulation could be achieved. ARIN legal staff has reviewed 2014-14,
remember, and found your argument lacking.
No, legal stated that there were no issues of liability for ARIN with the
policy. The potential for fraud was not stated one way or another by the
legal team in the staff and legal review.
First, where do you go to find 4,000 /16s? Not that I am accepting that
number, I argue the potential transfer market as more like 12,000 /16
equivalents (before more widespread CGN could enlarge that number).
I figure there are about 12 /8s or so that are well known to be
underutilized and that a proportional number of other blocks would account
for another 4 or so /8s worth of space. Admittedly, like any quantity
described at this point, it's mostly a SWAG, but I consider it a fairly
educated SWAG. YMMV.
Where do you get 12,000?
How do you negotiate quietly with the many, many sellers whom you would
have to spend a long time finding?
Why would you have to negotiate quietly?
Or would you put an ad in the NY Times and hope it escaped the notice of
the ARIN community, even though I assume it would be community members
engaging in at least one side of these transactions?
Why would an ad in the NY Times have to escape the notice of the ARIN
community?
Advertise that your organization would like to buy a /n (whatever size gets
passed with 2014-14 if it gets adopted).
Then, as the calls come in, change your org name after each successful call.
Nobody looking at the ad knows you're shopping for more than one. People who
compare notes think they're dealing with different organizations. I'm not
sure how you expect ARIN to put it together as the transfer requests come
in.
Do you think ARIN staff, a group that has processed a few hundred
transfers, would be able to even process those transactions in a timeframe
and manner invisible to policymakers?
It doesn't have to be invisible, it just has to look like a lot of different
unrelated transfers.
And what is the entity willing to engage in arguable fraud, who also has
the desire and finances to invest billions of dollars in an asset whose
value will decline with every new incentive to transition to IPv6?
You don't have to corner the market to manipulate it. You just need to
change its visible nature a little and then watch the lemmings do what you
encouraged them to do. Especially in a small market.
Or instead of one or two nefarious actors, you assume there would be many
smaller fraudsters engaging in enough rampant speculation to impact the
market.
I see no reason to believe that there would not be some combination of
actors across the spectrum. Under the proposed policy, they wouldn't even
necessarily be nefarious or operating fraudulent. A bit deceitful, perhaps,
but through omission rather than falsification if they played it right.
And how many flippers are active in a market with falling prices and an
asset value of zero?
You continue to assume falling prices, but there's nothing to indicate any
likelihood that will be the case for some time.
And if they flip them to a person who needs them, and makes money in the
process, what, exactly is the evil?
The evil is driving up the price for the person who had need and should have
been able to obtain them at the lower cost. I have no interest in turning
the IPv4 community resource pool into a source of monetization for parasites
who offer no value to the community in the process.
Where is the evidence of anyone, anywhere, buying Ipv4 addresses with an
intent to profit through their resale?
Unless you can provide some, why do we hold policy in thrall to the
bogeyman?
Since you are the one arguing for a change in policy, I believe the burden
of proof rests with you to prove that the policy will not damage the
interests of the community rather than placing the burden on me to prove
that it will.
I guess that's a long way of saying I would absolutely take your bet.
Unfortunately, since this is a case where what would be bet is the best
interests of the community, the stakes aren't mine to wager, nor are they
yours.
Owen
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