[rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 - Internet Number Resources Review by AFRINIC"

Thu Jul 20 12:41:06 UTC 2017

Daniel,

The problem here is deeper than what you see.

Firstly, there is nothing in any policy that requires an LIR to have an ASN to announce said space.
Secondly – there is nothing in any policy that states that IP addresses assigned to entity that is domiciled in the AFRINIC region must be utilized within the region – it simply isn’t there
Thirdly – There is nothing in any policy that prohibits charging for IP space – and in fact this is extremely common practice in many African ISPs (You get X number of IP addresses with the link you purchase, or a dynamic IP, if you want more, or you want static IP addresses, you pay extra)
Forth – One of the stated reasons that the LIR pricing from AFRINIC is so much higher than the end user pricing is that LIRs have the ability to recover the cost from the market – end users don’t.
Fifth – the requirements in the policy says that you have to have infrastructure to utilize the space – the problem with this is there is no definition of infrastructure – if you are assigning space to other entities and are legitimately swipping the space to those entities – the infrastructure you yourself require is a system that tracks how the space is assigned and a system capable of communicating the swip updates to AFRINIC – nothing more.

Now – let me state categorically – I oppose anyone charging for address space assigned by an RIR – if they have bought space on the secondary market and paid secondary market prices – then I can understand an attempt to regain the cost of said IP space – but beyond that – I have always taken the stance that ISP’s charging for space is a bad idea.  I do not however oppose the secondary market in the event of space being unavailable from an RIR.  I also do not dispute the requirements of needs based justification – though in an open secondary market it is my personal opinion that the need for this is reduced, since the economics involved will ensure adherence to needs base.

However, what it comes down to is this – if a cloud services provider, or a broker, can justify space within the bounds of policy – then the issues we face with individuals getting large amounts of space and leasing it out to people around the world – are our fault – because we did not modify the allocation policies.  We cannot blame those who use the policies as they are written and use the loopholes we choose to provide.  We have to take responsibility for not tightening the policies – not attempt to create audit policies and revocation policies to revoke space that was legitimately assigned within the bounds of policy.

Basically – what I am saying to this community is this – do not blame those who use the policies you yourself have passed – if you don’t like the policies – change them – and if you cannot get consensus on changing the policy then accept that the community does not agree this is a problem – that is what bottom up process is about.

For example – I will oppose any geographic restriction on where space can be used until such time as someone comes up with a concrete way to define geographic usage of space – something that has been attempted many times over the last few years and has failed every time.

Until such time as someone can concretely demonstrate that someone has been allocated space outside of allocation policies though – or is using them outside of the rules under which they are allocated – there is no cause to do anything – and auditing without evidence or without any concrete suspicion of violation of policy is simply not practical.  The real issue here is – the policies allow the behavior you describe – like it or not – and this community has chosen not to change those policies despite this issue being raised consistently over the last 5 or 6 years.

Andrew

From: Mwanguhya Daniel Murungi <dmurungi at techsupport.co.tz>
Organization: Techsupport Limited
Reply-To: "dmurungi at techsupport.co.tz" <dmurungi at techsupport.co.tz>
Date: Thursday, 20 July 2017 at 19:12
To: Mike Burns <mike at iptrading.com>
Cc: 'rpd List' <rpd at afrinic.net>
Subject: Re: [rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 - Internet Number Resources Review by AFRINIC"

Hello,

I came across this various services offered by Larus cloud services amongst them IPv4 sales/trading.

https://www.laruscloudservice.net/ip-delegation-service<https://www.laruscloudservice.net/ip-delegation-service>

Below is an excerpt from the site;

----------------------
[IP DELEGATION SERVICE]
LARUS has a mega pool of IPv4 addresses to provide unmatched IPv4 address solutions in the world. IP addresses will be delegated to you directly from Larus’s own IP pool. You will use the IP addresses like yours without limitation on geography and usage. This is a flexible and speedy service to meet your business needs.
----------------------

Honestly, I wonder how much IPv4 space from the AFRINIC pool is owned by the organization Larus Cloud Services?

I run a couple of whois queries and found the following:

(Organization) : whois -h whois.afrinic.net 'Larus Cloud Service'
----------------------

organisation: ORG-LCSL1-AFRINIC
org-name: Larus cloud service Limited
org-type: LIR
country: SC
address: C/o Abacus (Seychelles) Limited
address: Mont Fleuri, Mahe
phone: +359 897641784
phone: +852 2988 8918
admin-c: HL6-AFRINIC
tech-c: DH15-AFRINIC
mnt-ref: AFRINIC-HM-MNT
mnt-ref: LCSL1-MNT
mnt-by: AFRINIC-HM-MNT
source: AFRINIC # Filtered

person: David Hilario
address: Ul. Zaychar 54 floor 3, Apartment 11
address: Sofia 1309
address: Bulgaria
phone: +359 897641784
nic-hdl: DH15-AFRINIC
mnt-by: mine
source: AFRINIC # Filtered

person: Heng LU
address: Ebene
address: MU
address: Mahe
address: Seychelles
phone: +248 4 610 795
nic-hdl: HL6-AFRINIC
mnt-by: HLU
source: AFRINIC # Filtered
----------------------

Below is a list of resources held by Larus;

whois -h whois.afrinic.net -T aut-num -T inet6num -T inetnum -i og 'ORG-LCSL1-AFRINIC'

----------------------
inetnum: 196.251.244.0 - 196.251.247.255
netname: Larus-Cloud-v4
descr: Larus cloud service Limited
country: SC
org: ORG-LCSL1-AFRINIC
admin-c: HL6-AFRINIC
tech-c: DH15-AFRINIC
status: ALLOCATED PA
mnt-by: AFRINIC-HM-MNT
mnt-lower: LCSL1-MNT
source: AFRINIC # Filtered

person: David Hilario
address: Ul. Zaychar 54 floor 3, Apartment 11
address: Sofia 1309
address: Bulgaria
phone: +359 897641784
nic-hdl: DH15-AFRINIC
mnt-by: mine
source: AFRINIC # Filtered

person: Heng LU
address: Ebene
address: MU
address: Mahe
address: Seychelles
phone: +248 4 610 795
nic-hdl: HL6-AFRINIC
mnt-by: HLU
source: AFRINIC # Filtered

----------------------

One of the sub-allocations/assignment from above Block (196.251.244.0/22<http://196.251.244.0/22>) is actually assigned to some Saudi Arabia entity as per below whois query.

whois -h whois.afrinic.net -M '196.251.244.0 - 196.251.247.255'

----------------------
inetnum: 196.251.244.0 - 196.251.244.255
netname: SA-ITC-20120518
descr: Integrated Telecom Co. Ltd
country: SA
org: ORG-ITCL1-AFRINIC
admin-c: IR1052-AFRINIC
tech-c: IR1052-AFRINIC
status: ASSIGNED PA
mnt-by: LCSL1-MNT
mnt-routes: LCSL1-MNT
source: AFRINIC # Filtered

----------------------

Larus Cloud Services has no ASN and IPv6

whois -h whois.afrinic.net -T aut-num -T inet6num -i og 'ORG-LCSL1-AFRINIC'

Furthermore, I noticed that the domains laruscloudservice.net and cloudinnovation.org have the same owner.

----------------------
Domain Name: laruscloudservice.net
Registrant Name: Heng Lu
Registrant Organization: Larus Cloud Service Limited.
Registrant Street: 903 Dannies HSE
Registrant Street: 20 LUARD RD
Registrant City: WAN CHAI
Registrant State/Province: HONG KONG
Registrant Postal Code: 9741mh
Registrant Country: HK
Registrant Phone: +31.641734323
Registrant Phone Ext:
Registrant Fax:
Registrant Fax Ext:
Registrant Email: h.lu at outsideheaven.com

Domain Name: CLOUDINNOVATION.ORG
Registrant Name: Lu Heng
Registrant Organization: AnytimeChinese
Registrant Street: Esdoornlaan 656
Registrant City: Groningen
Registrant State/Province:
Registrant Postal Code: 9741MH
Registrant Country: NL
Registrant Phone: +31.641734323
Registrant Phone Ext:
Registrant Fax:
Registrant Fax Ext:
Registrant Email: er4tmx4khysehimnwr3s at l.o-w-o.info

----------------------

Cloud innovation
================

Cloud innovation and Larus Cloud share the same physical address and contacts:

whois -h whois.afrinic.net 'CLOUD INNOVATION'

----------------------
organisation: ORG-CIL1-AFRINIC
org-name: Cloud Innovation Ltd
org-type: LIR
country: SC
address: C/o Abacus (Seychelles) Limited
address: Mont Fleuri, Mahe
address: Seychelles
address: Mahe
phone: +248 4 610 795
phone: +248 4 610 795
admin-c: OS9-AFRINIC
tech-c: OS9-AFRINIC
mnt-ref: AFRINIC-HM-MNT
mnt-ref: CIL1-MNT
mnt-by: AFRINIC-HM-MNT
source: AFRINIC # Filtered
person: OutsideHeaven Support
nic-hdl: OS9-AFRINIC
address: Ebene
address: MU
address: Mahe
address: Seychelles
phone: +248 4 610 795
source: AFRINIC # Filtered

person: OutsideHeaven Support
nic-hdl: OS9-AFRINIC
address: Ebene
address: MU
address: Mahe
address: Seychelles
phone: +248 4 610 795
source: AFRINIC # Filtered

----------------------

In fact, Cloud Innovation Ltd has 2x /11 and 2x /12 IPv4 address space allocated to them:

whois -h whois.afrinic.net -r -T aut-num -T inet6num -T inetnum -i og 'ORG-CIL1-AFRINIC'

inetnum: 154.192.0.0 - 154.223.255.255
netname: Cloud-Innovation-v4-II
descr: Cloud Innovation Ltd
country: SC
org: ORG-CIL1-AFRINIC
admin-c: OS9-AFRINIC
tech-c: OS9-AFRINIC
status: ALLOCATED PA
mnt-by: AFRINIC-HM-MNT
mnt-lower: CIL1-MNT
source: AFRINIC # Filtered

inetnum: 154.80.0.0 - 154.95.255.255
netname: Cloud-Innovation-v4-I
descr: Cloud Innovation Ltd
country: SC
org: ORG-CIL1-AFRINIC
admin-c: OS9-AFRINIC
tech-c: OS9-AFRINIC
status: ALLOCATED PA
mnt-by: AFRINIC-HM-MNT
mnt-lower: CIL1-MNT
mnt-domains: CIL1-MNT
source: AFRINIC # Filtered

inetnum: 156.224.0.0 - 156.255.255.255
netname: CloudInnovation-infrastructure
descr: Cloud Innovation Ltd
country: SC
org: ORG-CIL1-AFRINIC
admin-c: OS9-AFRINIC
tech-c: OS9-AFRINIC
status: ALLOCATED PA
mnt-by: AFRINIC-HM-MNT
mnt-lower: CIL1-MNT
source: AFRINIC # Filtered

inetnum: 45.192.0.0 - 45.207.255.255
netname: Cloud-Innovation-v4-I
descr: Cloud Innovation Ltd
country: SC
org: ORG-CIL1-AFRINIC
admin-c: OS9-AFRINIC
tech-c: OS9-AFRINIC
status: ALLOCATED PA
mnt-by: AFRINIC-HM-MNT
mnt-lower: CIL1-MNT
mnt-domains: CIL1-MNT
source: AFRINIC # Filtered

Cloud Innovation Ltd just like Larus Cloud Services doesn't have any ASN and IPv6 as an LIR with so much space.

whois -h whois.afrinic.net -T aut-num -T inet6num -i og 'ORG-CIL1-AFRINIC'

Could all the above explain the vehement opposition of the people listed as contacts for both Larus Cloud Service and Cloud innovation [1]?

If so much IPv4 space/resources above was allocated to these LIR's for legitimate purposes, it should not be a problem. They will pass review and have ability to use the intra RIR transfer too.

Regards,
Daniel

[1] Heng Lu and David Hilario

On 2017-07-19 22:55, Mike Burns wrote:
Hi Noah,

There have been over 5,000 policy-compliant global IPv4 sales since
2010.

The concept is that the profit motive will incentivize those who hold
unused addresses make them available to sell them to somebody with a
need for them. This profit could be an incentive to renumber more
efficiently to free up blocks, or to provide some compensation for the
expense of that renumbering.

Without the profit motive, the only other motive is charity.

Charity has not proven to be effective in bringing unused addresses
back to those who need them, but a market has proven to be quite
effective.  That said, I know that at least two /8 holders voluntarily
returned their blocks to ARIN years ago.

A RIPE study revealed that most address sales are of older legacy
blocks that have not appeared in the routing table for a long time.

This is evidence that the lure of profit has functioned more
effectively than any prior threat of revocation to move addresses from
a low- or no-use environment and into the hands of those who need them
to run operational networks.

In order to foster this market, other registries have removed the
threat of revocation for utilization from their policies and RSAs in
order to make it clear to prospective sellers that the registries will
act as partners to address-holders seeking to sell, and not as judges
or juries with the power of revocation.

Yes, it is quite a shock that formerly public resources are now
yielding windfalls for address holders, but the importance of creating
a market to fulfill the needs of those seeking address has been judged
to outweigh the queasiness we may feel when witnessing the enrichment
of address-holders who sell their blocks.

If the role of AFRINIC is to get blocks into the hands of those who
need them, and the free pool is dry, what is the best way to answer
that need? One way is to audit, revoke, and recover unutilized space.
The other way is to harness the profit motive to lift unutilized
addresses to their “highest and best” use.

ARIN, APNIC, and RIPE debated these two options and chose the market
route. I think 5,000 transfers is evidence that the correct decision
was taken.

LACNIC has also chosen to allow a market for IPv4 addresses to
develop, but unlike the other registries, LACNIC has not removed the
threat of revocation in its policies and RSA.  A comparison in
transfer volume between the LACNIC region and the other regions
provides possible evidence that retaining the revocation threat is
detrimental to the market, as the volume in LACNIC is very, very low,
at 10 total transfers to date.

And surely you know that people will be buying and selling IPv4 in
Africa very soon:

https://www.afrinic.net/en/library/news/2085-afrinic-board-ratifies-policy-proposal-ipv4-resources-transfer-within-the-afrinic-region<https://www.afrinic.net/en/library/news/2085-afrinic-board-ratifies-policy-proposal-ipv4-resources-transfer-within-the-afrinic-region>

I have facilitated transfers to recipients in 60 countries, and soon
that will include African countries.  I am proud to have helped get
address blocks into the hands of the buyers in these countries, and
there is nothing “so-called” about IP brokerage. It’s a new
world, Noah, perhaps you should be the one bracing yourself.

Regards,

Mike Burns

IPTrading.com

FROM: Noah [mailto:noah at neo.co.tz<mailto:noah at neo.co.tz>]
SENT: Wednesday, July 19, 2017 3:22 PM
TO: Bill Woodcock <woody at pch.net<mailto:woody at pch.net>>
CC: rpd List <rpd at afrinic.net<mailto:rpd at afrinic.net>>
SUBJECT: Re: [rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 -
Internet Number Resources Review by AFRINIC"

On Jun 26, 2017, at 8:37 PM, Lu Heng <h.lu at anytimechinese.com<mailto:h.lu at anytimechinese.com>>
wrote:
This policy is in direct conflict with transfer policy, if someone
wants to sell their address space, they surely not commit to use it
with the original purpose, should AFRINIC instead of allowing them
to transfer the space, but reclaim them and redistribute them for
"better use"? If that is the case, the transfer policy will have no
use because of that.

Woow

So your worry is that someone will not be in a position to "sell" idle
IP address space through the transfer policy?

I always thought the fundamental premise was for INR's to be allocated
for use that can promote internet expansion rather than profit from
INR's.

On 12 Jul 2017 9:14 a.m., "Bill Woodcock" <woody at pch.net<mailto:woody at pch.net>> wrote:

I would just like to point out that the AfriNIC community does not
exist to serve the financial interests of those who wish to sell
addresses, rather than use them.

 + Bill

And whoever in their wildest thoughts think the community shall seat
back and see them trade IPv4 for any other reason beyond using them to
build infracture and extend internet related services in AFRICA should
brace themselves for now.

The AfriNIC community is the community of people who need IP
addresses, in order to route them and give people access to the
Internet.

+1 Bill

The AfriNIC policy process exists to serve those who wish to _use_
IP addresses, not those who wish to profit from them at the expense
of the community.

+1 Bill

Especially those who wish to profit from INR's especially the so
called IPv4 brokers. There is AFRINIC for goodness sake.

Cheers,

Noah
_______________________________________________
RPD mailing list
RPD at afrinic.net<mailto:RPD at afrinic.net>
https://lists.afrinic.net/mailman/listinfo/rpd<https://lists.afrinic.net/mailman/listinfo/rpd>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.afrinic.net/pipermail/rpd/attachments/20170720/5b2be008/attachment-0001.html>