IP Address News

Providing you with a single site about IP Addresses News and Usage

IP Address News - Providing you with a single site about IP Addresses News and Usage

Legacy IPv4 Address standing with USG

ARIN has posted a set of letters and links in response to a letter from the general counsel of the US National Science Foundation (NSF) that was circulated widely on the Internet in the fall of 2012.  This letter was previously written about in a blog entry here and the on Internet Governance Project website.

John Curran, the CEO of ARIN, wrote a letter to the general counsel of the NSF in response to the leaked private letter.  In the letter, Mr. Curran requested that the NSF revoke its previous letter or clarify the early IP address assignment context of the letter.  The letter also goes on the state ARIN’s case for why it believes it should be the registry of record for these legacy IP resource records and why they should be subject to the same community driven stakeholder policy process as IP address assignments made today by the RIRs.

In a letter, dated November 7th, 2012, the general counsel of the NSF responded to Mr. Curran’s letter and stepped back from some of the statements made previously in the earlier private letter.  Specifically noting that the NSF does not speak for the USG on the issue of Internet governance, the NTIA is the appropriate government agency to represent the USG in this area, and that the previous letter was a private letter observation on the NSF’s historical role in the development of the Internet.

This response now seems to erode the idea, that some members of the Internet community have posited, the NSF letter endorsed that legacy IP address assignments should be treated more like property rather than a resource licensed for a specific use.

ARIN’s website on their legacy address information page also now notes the following:

On December 3, 2012, the National Telecommunications and Information Administration (“NTIA”) formally commented on the USG’s Internet protocol numbering principles, including that it recognizes ARIN as the RIR for this region. This NTIA guidance is a clear response to the issues raised by an earlier letter from National Science Foundation General Counsel (NSF GC).

NTIA Administrator Lawrence Strickling posted a blog entry on the US Department of Commerce’s NTIA website clarifying the NTIA’s approach to IP addressing in the US.  In the blog entry, Mr. Strickling specifically notes that the USG supports the existing multistakeholder model for development of Internet technical standards and processes, that the RIRs “are responsible for developing policies for the use of IP numbers within their respective specific geographic regions,” ARIN is the RIR for the United States, and that the “USG believes that all IP numbers are allocated for use on a needs basis and should be returned to the numbering pool when no longer needed.”

For those, who still believe that legacy IP addresses should be outside of existing RIR framework and not subject the the needs based policies which have been supported by the Internet community for more than a decade, this series of events only appears to further strengthen the case that the legacy IP address assignments should fall under ARIN’s role as the registry of record and that the USG appears prepared to defend that position in the United States.


IPv6 Adoption Update

Iljitsch van Beijnum has recently published an update on IPv6 adoption: IPv6 takes one step forward, IPv4 two steps back in 2012.

The second page of his article mentions the economics of IPv6 deployment as reason for the slow deployment of IPv6.

Apparently, the economics of moving to IPv6 before we absolutely, positively had to without delay weren’t there. As with all technology, IPv6 gets better and cheaper over time. And just like with houses, people prefer waiting rather than buying when prices are dropping. To make matters worse, if you’re the only one adopting IPv6, this buys you very little.

And the pain of the shrinking IPv4 supplies versus the pain of having to upgrade equipment and software varies for different groups of Internet users.

All this means that organizations that are experiencing a lack of sufficient IPv4 addresses will have to address that problem in some other way: by having multiple users share a single IPv4 address through Network Address Translation (NAT).

This echos my thoughts on the matter when I wrote about them extensively in 2011.  Use of IPv4 NAT as a substitute for moving to IPv6 was one of the concerns that I and others have raised which could delay or deter IPv6 adoption.

A positive note on IPv6 deployment since 2011:  It does seem that IPv6 has been adopted permanently by a number of the large content providers, so at least one side of the transaction is there.  Further deployment of IPv6, in my opinion, now depends on the large cable and broadband providers.  Only when millions of those subscribers are converted to be IPv6 enabled will we see significant uptake in IPv6 traffic.

Lee Howard of Time Warner noted last year at the IETF 84 that just getting to 1% of current broadband subscribers is a significant effort.  At NANOG 56, Lee also noted that the economics of IPv4 xfers vs. carrier-grade NAT vs. IPv6 aren’t as simple as they might seem.

Legacy IPv4 Address “rights”

The Internet Governance Project (IGP) has posted a letter from the general counsel of the National Science Foundation regarding the status of Legacy IPv4 addresses.

In IGP’s commentary regarding the letter, they claim that this letter confirms a legacy holder’s right to “own their number blocks.”   While the letter is certainly an interesting read and its existence is somewhat curious, I don’t really believe this letter resolves anything.

The letter to me clearly states that the NSF general counsel believes that NSI under the NSF contract granted the organization which received the IPv4 Addresses certain rights to use those addresses.  Furthermore, the letter goes on to state that NSI did not and could not unilaterally revoke those rights and that the “NSF does not believe ARIN, or for that matter any other organization, could retroactively affect property and rights distributed to you.”

In a comment to the blog post, John Curran CEO of ARIN writes “The concern has never been about ARIN unilaterally reclaiming number resources; it has been about changes to the number resources in the registry and whether such changes must comply with community policy.  The letter further does not address in the least ARIN’s operation of the registry…”

My personal opinion is that the ambiguity that does exist regarding the relationship of Legacy IPv4 Address holders who has not signed a registration services agreement with an RIRs will not fully be resolved until a US federal court rules on the specific issues surrounding their status and specific “rights.”   It also seems likely that US federal law or regulation could also clear up any ambiguity, but a resolution method through the court system seems more likely.  Even then only further litigation can fully resolve any claims a legacy holder or ARIN claim to assert.

I encourage you to read the letter yourself to see what it does or does not say.


Study on IPv4 transfer market

The Internet Governance Project has released a study regarding the first IPv4 market transfers.

This report discusses what is known about the IPv4 market transfers which have occurred since the implementation of specified transfers within the ARIN, RIPE, and APNIC region.  The report brings together a number of sources to come up with the a total of 83 transactions representing 204 blocks for a total of 6 million IPv4 addresses traded between 2009 and the first half of 2012.

The data for IPv4 market transactions is obscured, however, due to the lack of transparency for all transactions.  While many have called for additional transparency, full transparency seems unlikely given the current constraints of the RIRs and the lack of other compelling regulations which would require disclosure of IPv4 market transactions.

As expected, the source of most of the transferred blocks are legacy IPv4 holders in the ARIN region.  The authors seem surprised that the majority of the transfers occurred in the ARIN region.  Given the expected supply for the IPv4 transfer market was expected to come from legacy IPv4 holders (who are largely in the ARIN region) and that an inter-RIR transfer policy was not in place until mid-2012, it is a logical conclusion that the majority of transfers would occur from and to ARIN region entities.

Unfortunately, I believe the study is also laden and interwoven with the authors opinions regarding the market rather than strictly focusing on the facts about the known market.

Full Report: http://www.internetgovernance.org/wordpress/wp-content/uploads/IPv4marketTPRC20121.pdf   (copy)

ARIN IPv4 transfer statistics 2011 and 2012 YTD

ARIN posted a message which some might have missed among the policy discussions going on the public policy mailing list (PPML).

ARIN Community –

Several folks have asked for more statistics regarding specified transfer
request processing.  While we are looking into options for producing such
information via automation, we have manually reviewed the past tickets to collect the following information:

In 2011, there was a total of 24 Specified Transfers (NRPM 8.3) requested.  
Below is the current status:

Total 8.3 transfers          24
Approved                          15
Pending/Abandoned      8
Denied                               1  (request was actually for simple reassignment)

In 2012 through July, there were a total of 19 Specified Transfers (NRPM 8.3) requested. Below is the current status.

Total of 8.3 transfers     18
Approved                          12
Pending/Abandoned      5
Denied                               1  (duplicate ticket)

Note that “Pending/Abandoned” is a request which lacks sufficient information from the requestor to process.  These may be still be in progress, or approved to transfer a lessor amount than requested and then not further pursued by the requestor.  Note also that some transfer requestors later return with a fully qualified recipient so that the address block may later be an approved transfer to another party in these statistics.

Original post is here:


Inter-RIR IPv4 transfers begin

ARIN announced today the implementation of the Inter-RIR IPv4 transfer policy (2011-1).  This policy, which has been discussed over the past two meetings was controversial for a number of reasons including that it would potentially move a lot of address space from the ARIN region to other regions.

Since the policy requires a compatible policy with each RIR only the APNIC region will currently be able to perform transfers under this policy.

ARIN has released new guidelines for “8.4 Inter-RIR Transfers to Specified Recipients”.

The announcement also included a note about a twitter discussion to be held August 8th to discuss the new policy.

ARIN XXIX meeting update

ARIN’s XXIX regional meeting in Vancouver, Canada concluded last week.  A couple of notable discussions occurred.

An updated IPv4 transfer policy 2012-1 was discussed alongside the 2011-1 inter-RIR transfer policy which is pending implementation and board adoption.  ARIN staff noted that the inter-RIR transfer policy will be ready for implementation in about 90 days.  I expect that the ARIN board will implement and move forward with implementing inter-RIR transfers using the revised 2012-1 text which is currently in last call on the public policy mailing list.

A policy 2012-3 to allow ASN numbers to be transferred in a method similar to the existing IPv4 transfers was recommended for last call.  While the circumstances for transfer are different compared with IPv4 transfers, ARIN’s general counsel is recommending that adopting the policy reduces legal liability for ARIN.  During the meeting it was also noted that there is an existing bankruptcy case pending which contains an ASN which has been requested to be transferred.  It seems likely that the board will adopt this policy in due time.

Finally, the community considered a policy 2012-4 to reverse the current 3 month supply restriction on IPv4 allocations.  This policy would have modified the policy to allow a 12-month supply while ARIN has at least a /8 equivalent in its free pool.  This policy would likely have caused the run-out in the ARIN region to proceed faster.  The policy was recently abandoned by the Advisory Council which indicates the current 3 month supply policy is likely to continue until ARIN’s IPv4 free pool is exhausted.


ARIN publishes commentary on transfers via bankruptcy

ARIN has published a commentary written by its legal counsel and two affiliates regarding the transfer of IPv4 addresses in the ARIN region.  The article, published in the Bloomberg BNA’s Bankruptcy Law Reporter, outlines the contract language that ARIN suggests buyers and sellers of IPv4 addresses use in their contracts to ensure a smooth and expedient transaction.

The commentary certainly outlines ARIN’s point of view of the legal and contract issues which exist regarding the transfers.  While some (e.g. legacy address holders) likely will disagree with some of the assertions in the commentary, this commentary does lay out ARIN’s stance, such as IP addresses are not property but “interest in the registration right to IP Numbers and the IP Numbers.”  While some organizations might choose to use the courts to assert alternate methods of transfer, those entities who generally would like a more expedient transfer process will likely benefit from following the advice contained within the article.

ARIN: Suggested Guidance for Bankruptcy Trustees, Debtors-in-Possession, and Receivers

Milton Mueller of the Internet Governance Project has also published on his blog a response to this guide.

ARIN propagandizes the bankruptcy bar