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

Mon Jul 24 14:59:21 UTC 2017

On 24/07/2017 16:39, Andrew Alston wrote:
>
> Actually, Marcus, you are **HALF** correct.
>
>  
>
> There is **NO** policy that prevents anyone from leasing IP space to a
> third party through sub-allocations – on provision that your
> application stated that you would assigning space to customers. 
> Indeed, this is a VERY common practice, and I can name MULTIPLE ISP’s
> on this continent that are charging their customers if the customer
> wants more than X number of IP addresses, on a recurring revenue
> basis.  It is **NOT** against any policy, the policies are ENTIRELY
> silent on if an LIR can charge for space that is assigned – and indeed
> – in previous discussions one of the reasons I have heard for LIR fees
> being far higher than end user fees is that LIR’s have the option to
> recover the costs from the customers.
>
>  
>
> Now – let me also state – I am vehemently opposed to the charging of
> customers for IP space – and it is something I do not believe any ISP
> should be doing – but – that is **personal opinion** - that is not
> what the policies say.
>

:-)

So essentially you build your AFRINIC fees for address space into what
you charge the Customer. However, if a Customer justifies more space,
you currently don't charge them for the extra space. That's fine.

:-)

> So to say that LIR’s are not allowed to “sell” IP addresses to their
> customers through sub-allocations or assignments – is only accurate if
> the sale is done on a permanent basis.  It is **ENTIRELY** within the
> policy to assign space, either through sub-allocation or through
> assignment, and it is **ENTIRELY** within the policy for the LIR to
> change whatever the hell they like for that service. 
>
>  
>
> It all depends on what was stated in the original application. 
>
>  
>
> Andrew
>
>  
>
>  
>
> *From: *"Marcus K. G. Adomey" <madomey at hotmail.com>
> *Date: *Monday, 24 July 2017 at 11:41
> *To: *"dmurungi at techsupport.co.tz" <dmurungi at techsupport.co.tz>, David
> Hilario <d.hilario at laruscloudservice.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"
>
>  
>
> 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
> <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
> >
> > 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
> <https://lists.afrinic.net/mailman/listinfo/rpd>
> >
> >
> > _______________________________________________
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> >
>
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-- 
Mark James ELKINS  -  Posix Systems - (South) Africa
mje at posix.co.za       Tel: +27.128070590  Cell: +27.826010496
For fast, reliable, low cost Internet in ZA: https://ftth.posix.co.za

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