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

Mon Jul 24 09:41:27 UTC 2017

Dear David,

I find your email rather strange if you can admit to selling/trading of IP Addresses.

At the current state of affairs, LIRs are not allowed to sell IP Addresses  to their customers through sub-allocations  and assignments.

Afrinic intra transfer policy is even yet to be implemented and its rules are also very clear on how resources can be transferred.

Passing additional allocations evaluation (and we trust Afrinic staff for always doing their job) is super.

Equally passing a resource utilization review is also a requirement and desirable by serious LIR's willing to prove to their customer's base  that their business is risk-free.

You're concerned by the impact of the policy on other members and not on your own LIR's  account?  Fantastic!!!

The PDWG is open and they are free to express themselves,

Your historical concerns  about deregistration, threat of legal risks to Afrinic and opposition of the review policy dictate the contrary of what you claimed here.

You clearly have a conflict of Interest in the discussions on this policy proposal and this must be taken into account.

Marcus

________________________________
From: David Hilario <d.hilario at laruscloudservice.net>
Sent: Thursday, July 20, 2017 12:50:54 PM
To: dmurungi at techsupport.co.tz
Cc: rpd List
Subject: Re: [rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 - Internet Number Resources Review by AFRINIC"

Hello Daniel,

Thank you for showing interest in our services.

If you have any questions, please feel free to direct them towards me
or to our generic email.

LIRs by definition are there to issue address space to their customers
and services.
Our operations are fully policy compliant, we have passed additional
reviews for each additional allocations issued by AFRINIC.

If you want more example of large allocations within AFRINIC you can
also check, you can easily sort by date and unique ID per resource
holder:
ftp://ftp.afrinic.net/pub/stats/afrinic/delegated-afrinic-extended-latest

It will help you find more LIRs with large allocated pools, all of
them  having passed the rigorous AFRINIC verifications before being
issued their allocations.

Now, my opposition against the review policy is not for our own
operations which you try to make it sound like.
We already passed so many checks and verification from AFRINIC during
each additional allocations that AFRINIC knows our network and
operations inside out.
So a review would be the least of our worries, and would in our case
be pretty straight forward and simple.

Secondly, why would we transfer away any of our space?
We are running a network with our clients using these IP address,
selling off IPs is only done when you are not needing your space
anymore, basically your company is going bust or your business
operations have changed.

David Hilario

IP Manager

Larus Cloud Service Limited

p: +852 29888918  m: +359 89 764 1784
f: +852 29888068
a: Flat B5, 11/F, TML Tower, No.3 Hoi Shing Road, Tsuen Wan, HKSAR
w: laruscloudservice.net
e: d.hilario at laruscloudservice.net

On 20 July 2017 at 14:12, Mwanguhya Daniel Murungi
<dmurungi at techsupport.co.tz> wrote:
> 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) 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
>
> 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
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>
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