I don’t entirely agree with this characterization.

In business, there is often a benefit to conserving cash up front even if it 
costs more capital over the long run. This is true of virtually every business 
lease and if it weren’t true and/or valid, there wouldn’t be so many companies 
providing leases to businesses for all manner of equipment and other assets, 
including cars.

Owen


> On Nov 1, 2019, at 9:19 AM, hostmas...@uneedus.com wrote:
> 
> I also agree with what has been said, and am also opposed to the proposal.
> 
> Some of the justification seems to be in the form of "I cannot afford to buy 
> a car, so I demand that someone permit me to lease one".  Noone is going to 
> get into the car leasing business unless they can make money. Generally the 
> only money making segment is going to be the short term, since the lessors 
> profit is going to make buying cheaper than leasing in the longer term.  I 
> think the same applies to IP leasing.
> 
> In the case of IP address leasing, the only major users of short term leases 
> are abusers.  The advancers of this proposal talk of longer term leases to 
> get discussion away from those abusers.  However, most of the time, someone 
> wanting a long term lease would be better off to buy, as they can always sell 
> them on again at the end of the need and often recover nearly all of their 
> original investment, effectively having a short term use of the address space 
> nearly free.  I think the long term IP leasing business model will not work.
> 
> The only valid leasing I can see is an entity that has excess address space 
> that they expect to use in the future, and I think that case is already 
> addressed in the current rules. They would also be unlikely to lease to 
> someone that is an abuser, since they will have to live with the block 
> reputation after the lease ends.
> 
> Albert Erdmann
> Network Administrator
> Paradise On Line Inc.
> 
> On Fri, 1 Nov 2019, Fernando Frediani wrote:
> 
>> Exactly, and the main justification for this proposal to allow subleasing  
>> is a total misuse of IP addressing and a try to privilege specific companies 
>> in
>> detriment to all others.
>> I do not agree that legitimizing leasing as such increases accessibility to 
>> IPv4 space. Organization already have access to it by transfers. By allowing
>> leasing as such prices of both leasing and transfer has the potential to 
>> rise significantly as organizations will prefer much more to sublease than to
>> transfer which is logic to think that will increase pricing in general for 
>> both and which is only interesting to those who are involved in the 
>> transaction
>> and not to those who are seeking for IPv4 space and have already access via 
>> transfers.
>> The point about keeping the correct registry updated is not a justification 
>> either because this is already a obligation. If someone is not doing that or 
>> is
>> doing things in a different way is going against the current policies. Any 
>> organization who signed a contract when they became a member accepted to 
>> follow
>> these rules and they must bound to them, not the other way round.
>> As said there is not reasons to issue addresses to anyone who will not be 
>> using them on a operational network other than legitimate speculation of IP 
>> space.
>> I consider the current text in NRPM as appropriate and therefore I oppose 
>> this proposal in full.
>> Regards
>> Fernando
>> On 01/11/2019 11:28, Owen DeLong wrote:
>>      I have trouble with both phrases.
>> Even if the resources are to be re-assigned to organizations or entities 
>> which do not receive connectivity from the original registrant, I see no
>> reason to issue addresses to anyone who will not be using them on an 
>> operational network.
>> Owen
>> 
>>      On Oct 31, 2019, at 3:10 PM, Scott Leibrand <scottleibr...@gmail.com> 
>> wrote:
>> On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil <k...@openiadvisors.com> 
>> wrote:
>>      Dear All,
>> Prior to tomorrow's community discussion of Draft Policy ARIN-2019-18, I 
>> wanted to offer some clarification and propose some language for
>> consideration to address questions posed on the PPML.
>> Regarding the question over the intended meaning of "non-connected 
>> networks", I will clarify that I mean this policy to refer to
>> re-assignment to organizations and entities which do not receive 
>> connectivity from the original registrant.  
>> As such, I wanted to offer the following alternative edit to 8.5.2: 
>> 
>>      8.5.2 Operational Use
>> ARIN allocates or assigns number resources to organizations via transfer 
>> primarily for the purpose of use on an operational network,
>> but may allocate or assign number resources to organizations for other 
>> purposes, including re-assignment to organizations and
>> entities which do not receive connectivity from the original registrant.
>> I believe this is consistent with the intent of 2019-18, and I would support 
>> this language.
>>  
>> Alternatively, and more simply, since the sentence referencing 
>> "non-connected networks" starts with "including" and is therefore not meant
>> to be an exclusive "other purpose", but rather illustrative, we can remove 
>> it entirely.  That option would read: 
>> 
>>      8.5.2 Operational Use
>> ARIN allocates or assigns number resources to organizations via transfer 
>> primarily for the purpose of use on an operational network,
>> but may allocate or assign number resources to organizations for other 
>> purposes.  
>> I believe this is materially different than the text above, in that it would 
>> give ARIN permission to approve transfers for any reason
>> whatsoever. ARIN in the past has interpreted such ambiguity in favor of 
>> allowing whatever is not expressly prohibited. As such, I don't think
>> this language accomplishes the original intent, and would oppose it.
>> -Scott
>>  
>> 
>>            *please note that the online version of the policy proposal reads 
>> "solely primarily" instead of "primarily".  This is a
>>            typo due to originally proposing the language with the word 
>> "solely" in strike-through text (solely), which did not
>>            translate.  
>> Further, I want to clarify, as the original author of the proposal, that the 
>> key intent of the policy is to acknowledge that small and
>> medium-sized businesses have a need for IPv4 space, but often cannot afford 
>> to buy space in the current market.  Legitimizing a subleasing
>> market increases accessibility to IPv4 space, and opens the market to 
>> business solutions to facilitate safe, trusted subleasing practices,
>> including keeping the correct registry updated.  
>> Thanks all for the continued discussion.  
>> Best,
>> Kiran
>> --
>> Kiran Malancharuvil
>> Open-i Advisors      
>> p:  415 419 9138
>> http://openiadvisors.com
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