John,

The fact that there are no reported cases (yet) ordering ARIN to update its 
registry due to an abridgement of property rights isn’t evidence that the legal 
analysis is incorrect.  It’s never easy or trivial to prevail in litigation 
when strong interests sit in opposition -- even if the law clearly favors the 
harmed party.  Discovery tactics, procedural motions, and pre- and 
post-litigation settlements are all effective tools defendants use to keep 
disputed matters from going to trial (especially where the matter is of 
considerable interest and there is a risk of setting undesirable legal 
precedent).

With respect to the property question, under your scenario (with trial plus 
appeal), winning such a case would be long and expensive for the harmed party.  
And only worth doing if a less expensive and reasonable resolution were not 
otherwise available.  Until very recently, ARIN could avoid any material harm 
caused by wrongfully dispossessing a registrant of its numbers by just issuing 
the affected entity additional numbers.   Now that the free pool is virtually 
depleted and IPv4 numbers have economic value, I anticipate that there will be 
more formal disputes involving ARIN and the issue of property rights with the 
increased probability of trial and appeal -- particularly where ARIN takes the 
position that it alone gets to pick the winner and loser in a dispute between 
parties making claim to the same resource.

But this isn’t the principle reason to consider the issue more closely from a 
policy perspective.   ARIN could easily mitigate its risk.  And in the 
post-exhaustion / transfer market context, whatever risk there is for ARIN in 
operating under a property regime is outweighed by the benefits to IPv4 
registrants.  With legally recognized property rights, current registrants and 
transfer recipients will have well established legal remedies to enforce the 
uniqueness of their address space and, for transferees, to protect their 
purchases.

Regarding your last point, finding property rights in IPv4 numbers does not 
require a genesis moment or an express grant by the USG.  Nothing in the common 
law makes these prerequisites.  Pre-existing (non-property) resources can 
evolve into property.  And property rights can vest in a current 
possessor/holder where the prior owner is unknown, or unwilling or unable to 
enforce its rights (e.g., adverse possession and abandonment).

Marc Lindsey
Avenue4 LLC
2001 L Street, N.W.
Suite 900
Washington, D.C. 20036
Direct: (202) 741-9521
Mobile: (202) 491-3230
www.Avenue4LLC.com<http://www.avenue4llc.com/>



From: John Curran [mailto:[email protected]]
Sent: Thursday, June 04, 2015 11:48 AM
To: Marc Lindsey
Cc: [email protected]
Subject: Re: [arin-ppml] On USG 'granting of rights'

On Jun 4, 2015, at 11:12 AM, Marc Lindsey 
<[email protected]<mailto:[email protected]>> wrote:

A court asked to decide on the property status of IPv4 numbers would, by 
operation of judicial precedents, apply this property law test because it is 
readily extendable to IPv4 numbers.  We  would also expect that, applying this 
test, the court would reach the same conclusion the Ninth Circuit did with 
respect to domain names: (1) IP number registrants have sole authority to 
decide how their numbers will be used within the Internet; (2) registrants have 
the right and authority to use IPv4 numbers exclusively for routing over the 
public Internet; and (3) like domain names, registrants are reflected in an 
authorized Internet registry, which "informs others that the [IPv4 number] is 
the registrant's and no one else's."  IPv4 numbers, like domain names, are now 
considered a valuable asset, and like domain names, they possess all of the 
requisite ingredients of private property.

If your supposition is correct, then it should be a trivial matter for any party
which feels their alleged “property rights” have been abridged to seek legal
relief, so as to obtain an order directing ARIN to update the registry contrary
to policy.   This has not occurred to date - instead, we have a string of 
results
which have ARIN updating the registry in compliance with its community policy.

The Kremen v. Cohen case also sheds some light on why ARIN firmly (and 
rationally) advocates the position that IP addresses are not property. The 
Kremen court found that the domain name registry at the time, Network 
Solutions, could be held liable for wrongfully converting another's property 
where it failed to observe an appropriate duty of care in maintaining and 
updating its registry records.

Actually, my principle concern is that the community currently maintains an
expectation regarding the application of registry policies in processing of
transfers, and this would be become difficult under a “IP property address”
regime.   Additionally, it is unclear if any party has the authority to 
recognize
the transfers of US Government property or whether we at the registry are
supposed to be simply recording the present party to whom these have been
issued.

Thanks,
/John

John Curran
President and CEO
ARIN


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