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

Thu Jul 20 13:40:37 UTC 2017

Dear Andrew, 

Thank you for your eloquence and timely reply. You have provided a
boatload of information that a large percentage of the community is not
really aware of or have simply chosen to ignore. Honestly, a part of my
brain just went 'poof'. 

Kindly allow me to internalize and I will revert. 

Regards, 
Daniel 

On 2017-07-20 15:41, Andrew Alston wrote: 

> 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
> 
> 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 [1 [1]]) 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 [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 [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 
> 
>> 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]
>> SENT: Wednesday, July 19, 2017 3:22 PM
>> TO: Bill Woodcock <woody at pch.net>
>> 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"
>> 
>> On Jun 26, 2017, at 8:37 PM, Lu Heng <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> 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
> https://lists.afrinic.net/mailman/listinfo/rpd 
> 
> Links:
> ------
> [1] http://196.251.244.0/22

Links:
------
[1] http://196.251.244.0/22
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