Hi Bill,

I understand there are ways to effectively circumvent ARIN policy through legal 
relationships.
But it's just simpler to create a thin VPN or to operate out of the RIPE RIR.
My point is that ARIN policy doesn't prevent leasing, it only restricts lessors 
to incumbent holders and thwarts newcomers. And current policy doesn't seem to 
have broken anything.

You can't go to ARIN and simply predict you will have X customers within two 
years and receive transfer pre-approval. The same rules would apply here, the 
same initial block size and protections, everything in justification remaining 
the same as it is for those who used to be called ISPs. Except historically 
ISPs could use their SWIPed addresses to show utilization only if they were 
connected to their clients by a circuit. They still have to be real clients, 
they still have to deployed on an operating network, they will still be 
required to submit evidence of that to ARIN.

Regards,
Mike


-----Original Message-----
From: William Herrin <b...@herrin.us> 
Sent: Friday, March 11, 2022 12:28 PM
To: Mike Burns <m...@iptrading.com>
Cc: PPML <arin-ppml@arin.net>
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

On Fri, Mar 11, 2022 at 6:25 AM Mike Burns <m...@iptrading.com> wrote:
> Are you against all renting of IPv4 addresses, and if so, why?
> Or are you against only non-incumbent owners renting space?

Hi Mike,

I would suggest that if you really want to lease addresses without 
infrastructure there are lawful and compliant ways to do so without change to 
ARIN policy. For example:

The broker and user of the addresses might form a legal partnership.
The address user would have the right to terminate its participation in the 
partnership comparable to a lessor's terms for ending a lease.
The broker would have the right, upon termination of the partnership, to resell 
the numbers compliant with ARIN rules and would retain the proceeds of such 
sale.
Finally the partnership, including both the practicing user and the purchasing 
broker, would request addresses through ARIN and, upon approval, purchase them 
on the open market. Because the partnership is, in fact, deploying a network 
which uses the addresses, such a use is compliant with ARIN policy.

While more complicated than a simple lease agreement, such a process would 
assure compliance with the community's then-extant number policies. In 
particular, the actual user of the addresses would be evaluated by ARIN and 
would have to qualify.

Even were I to find such "leasing" objectionable, I would have no cause for 
objection under current ARIN policy.

I note that once the initial template development is complete, instancing such 
legal partnerships is of trivial cost.

Regards,
Bill Herrin


--
William Herrin
b...@herrin.us
https://bill.herrin.us/

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