Hey Denis Walker, in 2019 until the end of december the last /22 allocation was assigned to the members/Lirs, once the ripe stopped assigning /22, there was not that much interest in 2020 for only a /24 subnet. And no, it was not free! Since in 2021 the price per IP skyrocketed, and ripe announced that they are out of stock, due because of this and due because the price per IP is going to the moon, the LIRs (mostly big boys) with multiple allocations started to apply for more and believe me they are making a good profit from this. For now is 200€/month is the price for /24 subnet to rent out, and it will be higher and higher. Cheers. -- *Sinqerisht / Sincerely,* AlbHost [image: Logo] <https://www.albahost.net/> Albanian Hosting SH.P.K. Besim Beka p.n. 50000 Gjakovë, Kosovë. NIPT/VAT ID: 811442657 T: +386900501502 E: info@albahost.net W*: *wWw.AlbaHost.Net <http://www.albahost.net/> [image: Facebook icon] <https://www.facebook.com/albanianhosting> [image: Twitter icon] <https://twitter.com/albahost> [image: Instagram icon] <https://www.instagram.com/albahost_vpn/> [image: Banner] Përmbajtja e këtij emaili është konfidenciale dhe ka për qëllim marrësin e specifikuar vetëm në mesazh. Ndalohet rreptësisht shpërndarja e ndonjë pjese të këtij mesazhi me ndonjë palë të tretë, pa pëlqimin me shkrim të dërguesit. Nëse e keni marrë këtë mesazh gabimisht, ju lutemi përgjigjuni këtij mesazhi dhe ndiqni me fshirjen e tij, në mënyrë që të sigurohemi që një gabim i tillë të mos ndodhë në të ardhmen. The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future.
Hi, We’re a start-up – and need a small allocation of IPv4 to connect our platform and to start generating revenue for our business. For us, even the RIPE joining and annual fees are a sizeable cost – and then having to pay around €10K for a /24 is a real problem. Unfortunately, we need to connect to the GRX network – so IPv6 is not an option, and nor is using a suballocation from a third party. We’re on the waiting list – but seemingly not going anywhere fast. I realize that it’s inevitable that a hot market will emerge for such a precious resource – but it is disappointing that those new businesses who genuinely need a small allocation for their originally intended use (connectivity) are hindered by those who just speculate with no intention of actually using the addresses. I am new to the scene and so unfortunately don’t have any useful suggestions to make – but it seems that something has to change since the current dynamic seems abusive. Regards, Mike Bromwich mike.bromwich@stacuity.com
Heya, Good (well, not really) to see that we are not the only ones with this experience, As i have stated above we are very small as well and are in need of the allocations for our business, for us too the annual fees and administration regarding them were an absolutely deciding factor in why we held off for so long. However, that doesn't mean I am against the fee. quite the opposite due to what it is used for. Welcome to the gang I guess? However, I was informed that we should be seeing allocations hit us no later than the end of January as things look right now. I can't guarantee that is the case for you. But hopefully it is. Regards, Mathias W. On Mon, Dec 13, 2021 at 5:40 PM Mike Bromwich <mike.bromwich@stacuity.com> wrote:
Hi,
We’re a start-up – and need a small allocation of IPv4 to connect our platform and to start generating revenue for our business. For us, even the RIPE joining and annual fees are a sizeable cost – and then having to pay around €10K for a /24 is a real problem. Unfortunately, we need to connect to the GRX network – so IPv6 is not an option, and nor is using a suballocation from a third party. We’re on the waiting list – but seemingly not going anywhere fast.
I realize that it’s inevitable that a hot market will emerge for such a precious resource – but it is disappointing that those new businesses who genuinely need a small allocation for their originally intended use (connectivity) are hindered by those who just speculate with no intention of actually using the addresses.
I am new to the scene and so unfortunately don’t have any useful suggestions to make – but it seems that something has to change since the current dynamic seems abusive.
Regards,
Mike Bromwich
mike.bromwich@stacuity.com --
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Hi Guys I have some more questions now as I dig deeper into these allocations. Marco mentioned in his email that the situation is quite fluid because of consolidations, transfers, and opening of new LIR accounts that occur all the time. I have found the transfer information, where can I find details of consolidations? Also is the waiting list published anywhere? I have seen companies with say 25 LIRs where 22 have already received a /24 this year. I would like to know if the other 3 LIRs are on the waiting list and at what position. Now I have some detailed questions about what is meant by consolidation. I will illustrate with an anonymous example. For all my analysis I will not identify any company by name. My intention is to expose behaviour. So we have a parent company ABC Networks BV. They set up 5 child companies. One in 2017 and 4 in early 2019. One of them is XYZ Networks BV. XYZ networks BV opens 12 LIRs. Throughout 2019 each of these LIRs receive a /22 allocation. In December 2019 all these LIRs/allocations moved to the parent company ABC Networks BV and the child company XYZ Networks BV was deregistered according to the Chamber of Commerce. In total the 5 child companies opened 50 LIRs. They each received a /22 throughout 2019 and all these child companies were deregistered in December 2019 with their LIRs/allocations 'transferred' to the parent company. Is this what is meant by consolidation? Not sure what the business case is to register several companies who open several LIRs each to get allocations, then close the companies a few months later and merge all the resources into the parent company...unless it is to try to hide the true number of LIRs the parent company has set up. The timing is also interesting. All of these child companies were merged with the parent company on 2 December 2019, according to the Chamber of Commerce: "Merger deed passed on 02-12-2019. Acquiring legal entity: ABC Networks BV Disappearing legal entities: XYZ Networks BV..." The child companies were then all deregistered on 5 December 2019, according to the Chamber of Commerce: "As of 5-12-2019, the legal entity has been deregistered due to Termination of registration" According to the Transfer Statistics the date of the transfer of the resources was 23 December 2019 from the child company XYZ Networks BV to the parent company ABC Networks BV. The ORGANISATION objects in the RIPE Database were also modified on 23 December 2019 to change the "org-name:" to that of the parent company ABC Networks BV. But the child company XYZ Networks BV did not exist on 23 December 2019. So was this a valid transfer? This applies to all 50 of the allocated resources to these child companies's LIRs. I suspect that when the merger took place on 2 December 2019 the parent company took legal ownership of the assets of the child company, including the LIR accounts with the allocated resources. That means the transfer actually took place on 2 December 2019, not the 23 December 2019 as stated in the Transfer Statistics. That makes the Transfer Statistics wrong. If this is meant to be a legal document that is not good. Something needs to be tightened up here. Maybe it is a chicken & egg situation. The merger has to legally occur and documents supplied to the RIPE NCC before the transfer can be acknowledged. But then the transfer stats should make it clear the transfer actually took place on 2 December when the merger occurred, not the date it was acknowledged by the RIE NCC on 23 December. It is also not clear to me what has actually been transferred/acquired? Is it the allocations or the LIR accounts with the allocations? In the delegated stats there still exists several entries for nl.xyz1, nl.xyz2, etc. These all refer to the legal name of the parent company ABC Networks BV. Does this mean the parent company has taken control (acquired) all 50 of these LIR accounts with their allocations, not just the allocations? Is this still a consolidation? Another general question. When a whole resource is transferred (within RIPE region) it looks like the RIPE NCC deletes and recreates the allocation object in the RIPE Database with 'todays' date as the creation date. But the entry in the delegated stats keeps the original allocation date. Is this how it is meant to be documented? (A good example of why a historical query in the RIPE Database should show the full history.) None of this is explained very well, or at all, in the policies or documentation. It assumes people know a lot more about this registration stuff than a database expert does (but I am learning). If someone can answer these points it may well help some of the new LIRs as well. I am sure there is a steep learning curve here for the newbies. cheers denis co-chair DB-WG On Mon, 13 Dec 2021 at 17:17, Albanian Hosting SH.P.K. via address-policy-wg <address-policy-wg@ripe.net> wrote:
Hey Denis Walker,
in 2019 until the end of december the last /22 allocation was assigned to the members/Lirs, once the ripe stopped assigning /22, there was not that much interest in 2020 for only a /24 subnet. And no, it was not free! Since in 2021 the price per IP skyrocketed, and ripe announced that they are out of stock, due because of this and due because the price per IP is going to the moon, the LIRs (mostly big boys) with multiple allocations started to apply for more and believe me they are making a good profit from this. For now is 200€/month is the price for /24 subnet to rent out, and it will be higher and higher.
Cheers.
-- *Sinqerisht / Sincerely,* AlbHost [image: Logo] <https://www.albahost.net/>
Albanian Hosting SH.P.K. Besim Beka p.n. 50000 Gjakovë, Kosovë. NIPT/VAT ID: 811442657 T: +386900501502 E: info@albahost.net
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Përmbajtja e këtij emaili është konfidenciale dhe ka për qëllim marrësin e specifikuar vetëm në mesazh. Ndalohet rreptësisht shpërndarja e ndonjë pjese të këtij mesazhi me ndonjë palë të tretë, pa pëlqimin me shkrim të dërguesit. Nëse e keni marrë këtë mesazh gabimisht, ju lutemi përgjigjuni këtij mesazhi dhe ndiqni me fshirjen e tij, në mënyrë që të sigurohemi që një gabim i tillë të mos ndodhë në të ardhmen.
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In order to prevent resource allocation abuse like these examples, RIPE should introduce a significant one time fee for resource transfer(s) due to LIR membership mergers or acquisitions. In case the LIR member being merged or acquired can verify reasonable network activities (not just collecting IPv4 resources for the sake of making profits later), this one time fee will be deductible from the LIR membership fees of the buyer in the upcoming years. So it should not have any effect on reasonable transactions due to mergers or acquisitions but block making profits for IPv4 traders. -Florian
Hi Guys
I have some more questions now as I dig deeper into these allocations. Marco mentioned in his email that the situation is quite fluid because of consolidations, transfers, and opening of new LIR accounts that occur all the time. I have found the transfer information, where can I find details of consolidations? Also is the waiting list published anywhere? I have seen companies with say 25 LIRs where 22 have already received a /24 this year. I would like to know if the other 3 LIRs are on the waiting list and at what position.
Now I have some detailed questions about what is meant by consolidation. I will illustrate with an anonymous example. For all my analysis I will not identify any company by name. My intention is to expose behaviour.
So we have a parent company ABC Networks BV. They set up 5 child companies. One in 2017 and 4 in early 2019. One of them is XYZ Networks BV.
XYZ networks BV opens 12 LIRs. Throughout 2019 each of these LIRs receive a /22 allocation. In December 2019 all these LIRs/allocations moved to the parent company ABC Networks BV and the child company XYZ Networks BV was deregistered according to the Chamber of Commerce.
In total the 5 child companies opened 50 LIRs. They each received a /22 throughout 2019 and all these child companies were deregistered in December 2019 with their LIRs/allocations 'transferred' to the parent company. Is this what is meant by consolidation? Not sure what the business case is to register several companies who open several LIRs each to get allocations, then close the companies a few months later and merge all the resources into the parent company...unless it is to try to hide the true number of LIRs the parent company has set up.
The timing is also interesting. All of these child companies were merged with the parent company on 2 December 2019, according to the Chamber of Commerce: "Merger deed passed on 02-12-2019. Acquiring legal entity: ABC Networks BV Disappearing legal entities: XYZ Networks BV..." The child companies were then all deregistered on 5 December 2019, according to the Chamber of Commerce: "As of 5-12-2019, the legal entity has been deregistered due to Termination of registration"
According to the Transfer Statistics the date of the transfer of the resources was 23 December 2019 from the child company XYZ Networks BV to the parent company ABC Networks BV. The ORGANISATION objects in the RIPE Database were also modified on 23 December 2019 to change the "org-name:" to that of the parent company ABC Networks BV. But the child company XYZ Networks BV did not exist on 23 December 2019. So was this a valid transfer? This applies to all 50 of the allocated resources to these child companies's LIRs.
I suspect that when the merger took place on 2 December 2019 the parent company took legal ownership of the assets of the child company, including the LIR accounts with the allocated resources. That means the transfer actually took place on 2 December 2019, not the 23 December 2019 as stated in the Transfer Statistics. That makes the Transfer Statistics wrong. If this is meant to be a legal document that is not good. Something needs to be tightened up here. Maybe it is a chicken & egg situation. The merger has to legally occur and documents supplied to the RIPE NCC before the transfer can be acknowledged. But then the transfer stats should make it clear the transfer actually took place on 2 December when the merger occurred, not the date it was acknowledged by the RIE NCC on 23 December.
It is also not clear to me what has actually been transferred/acquired? Is it the allocations or the LIR accounts with the allocations? In the delegated stats there still exists several entries for nl.xyz1, nl.xyz2, etc. These all refer to the legal name of the parent company ABC Networks BV. Does this mean the parent company has taken control (acquired) all 50 of these LIR accounts with their allocations, not just the allocations? Is this still a consolidation?
Another general question. When a whole resource is transferred (within RIPE region) it looks like the RIPE NCC deletes and recreates the allocation object in the RIPE Database with 'todays' date as the creation date. But the entry in the delegated stats keeps the original allocation date. Is this how it is meant to be documented? (A good example of why a historical query in the RIPE Database should show the full history.)
None of this is explained very well, or at all, in the policies or documentation. It assumes people know a lot more about this registration stuff than a database expert does (but I am learning). If someone can answer these points it may well help some of the new LIRs as well. I am sure there is a steep learning curve here for the newbies.
cheers denis co-chair DB-WG
Very interesting! Good catch. And thank you for the information provided, i personally believe that there is no help as because nobody cares at least not the RIPE NCC itself. I do believe that we all are wasting our time here, as long as my small company need a /22 allocation and cannot get it, it's worthless. We are renting them from others in order to survive! On Tue, Dec 14, 2021 at 2:20 PM denis walker <ripedenis@gmail.com> wrote:
Hi Guys
I have some more questions now as I dig deeper into these allocations. Marco mentioned in his email that the situation is quite fluid because of consolidations, transfers, and opening of new LIR accounts that occur all the time. I have found the transfer information, where can I find details of consolidations? Also is the waiting list published anywhere? I have seen companies with say 25 LIRs where 22 have already received a /24 this year. I would like to know if the other 3 LIRs are on the waiting list and at what position.
Now I have some detailed questions about what is meant by consolidation. I will illustrate with an anonymous example. For all my analysis I will not identify any company by name. My intention is to expose behaviour.
So we have a parent company ABC Networks BV. They set up 5 child companies. One in 2017 and 4 in early 2019. One of them is XYZ Networks BV.
XYZ networks BV opens 12 LIRs. Throughout 2019 each of these LIRs receive a /22 allocation. In December 2019 all these LIRs/allocations moved to the parent company ABC Networks BV and the child company XYZ Networks BV was deregistered according to the Chamber of Commerce.
In total the 5 child companies opened 50 LIRs. They each received a /22 throughout 2019 and all these child companies were deregistered in December 2019 with their LIRs/allocations 'transferred' to the parent company. Is this what is meant by consolidation? Not sure what the business case is to register several companies who open several LIRs each to get allocations, then close the companies a few months later and merge all the resources into the parent company...unless it is to try to hide the true number of LIRs the parent company has set up.
The timing is also interesting. All of these child companies were merged with the parent company on 2 December 2019, according to the Chamber of Commerce: "Merger deed passed on 02-12-2019. Acquiring legal entity: ABC Networks BV Disappearing legal entities: XYZ Networks BV..." The child companies were then all deregistered on 5 December 2019, according to the Chamber of Commerce: "As of 5-12-2019, the legal entity has been deregistered due to Termination of registration"
According to the Transfer Statistics the date of the transfer of the resources was 23 December 2019 from the child company XYZ Networks BV to the parent company ABC Networks BV. The ORGANISATION objects in the RIPE Database were also modified on 23 December 2019 to change the "org-name:" to that of the parent company ABC Networks BV. But the child company XYZ Networks BV did not exist on 23 December 2019. So was this a valid transfer? This applies to all 50 of the allocated resources to these child companies's LIRs.
I suspect that when the merger took place on 2 December 2019 the parent company took legal ownership of the assets of the child company, including the LIR accounts with the allocated resources. That means the transfer actually took place on 2 December 2019, not the 23 December 2019 as stated in the Transfer Statistics. That makes the Transfer Statistics wrong. If this is meant to be a legal document that is not good. Something needs to be tightened up here. Maybe it is a chicken & egg situation. The merger has to legally occur and documents supplied to the RIPE NCC before the transfer can be acknowledged. But then the transfer stats should make it clear the transfer actually took place on 2 December when the merger occurred, not the date it was acknowledged by the RIE NCC on 23 December.
It is also not clear to me what has actually been transferred/acquired? Is it the allocations or the LIR accounts with the allocations? In the delegated stats there still exists several entries for nl.xyz1, nl.xyz2, etc. These all refer to the legal name of the parent company ABC Networks BV. Does this mean the parent company has taken control (acquired) all 50 of these LIR accounts with their allocations, not just the allocations? Is this still a consolidation?
Another general question. When a whole resource is transferred (within RIPE region) it looks like the RIPE NCC deletes and recreates the allocation object in the RIPE Database with 'todays' date as the creation date. But the entry in the delegated stats keeps the original allocation date. Is this how it is meant to be documented? (A good example of why a historical query in the RIPE Database should show the full history.)
None of this is explained very well, or at all, in the policies or documentation. It assumes people know a lot more about this registration stuff than a database expert does (but I am learning). If someone can answer these points it may well help some of the new LIRs as well. I am sure there is a steep learning curve here for the newbies.
cheers denis co-chair DB-WG
On Mon, 13 Dec 2021 at 17:17, Albanian Hosting SH.P.K. via address-policy-wg <address-policy-wg@ripe.net> wrote:
Hey Denis Walker,
in 2019 until the end of december the last /22 allocation was assigned to the members/Lirs, once the ripe stopped assigning /22, there was not that much interest in 2020 for only a /24 subnet. And no, it was not free! Since in 2021 the price per IP skyrocketed, and ripe announced that they are out of stock, due because of this and due because the price per IP is going to the moon, the LIRs (mostly big boys) with multiple allocations started to apply for more and believe me they are making a good profit from this. For now is 200€/month is the price for /24 subnet to rent out, and it will be higher and higher.
Cheers.
-- *Sinqerisht / Sincerely,* AlbHost [image: Logo] <https://www.albahost.net/>
Albanian Hosting SH.P.K. Besim Beka p.n. 50000 Gjakovë, Kosovë. NIPT/VAT ID: 811442657 T: +386900501502 E: info@albahost.net
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Përmbajtja e këtij emaili është konfidenciale dhe ka për qëllim marrësin e specifikuar vetëm në mesazh. Ndalohet rreptësisht shpërndarja e ndonjë pjese të këtij mesazhi me ndonjë palë të tretë, pa pëlqimin me shkrim të dërguesit. Nëse e keni marrë këtë mesazh gabimisht, ju lutemi përgjigjuni këtij mesazhi dhe ndiqni me fshirjen e tij, në mënyrë që të sigurohemi që një gabim i tillë të mos ndodhë në të ardhmen.
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-- *Sinqerisht / Sincerely,* AlbHost [image: Logo] <https://www.albahost.net/> Albanian Hosting SH.P.K. Besim Beka p.n. 50000 Gjakovë, Kosovë. NIPT/VAT ID: 811442657 T: +386900501502 E: info@albahost.net W*: *wWw.AlbaHost.Net <http://www.albahost.net/> [image: Facebook icon] <https://www.facebook.com/albanianhosting> [image: Twitter icon] <https://twitter.com/albahost> [image: Instagram icon] <https://www.instagram.com/albahost_vpn/> [image: Banner] Përmbajtja e këtij emaili është konfidenciale dhe ka për qëllim marrësin e specifikuar vetëm në mesazh. Ndalohet rreptësisht shpërndarja e ndonjë pjese të këtij mesazhi me ndonjë palë të tretë, pa pëlqimin me shkrim të dërguesit. Nëse e keni marrë këtë mesazh gabimisht, ju lutemi përgjigjuni këtij mesazhi dhe ndiqni me fshirjen e tij, në mënyrë që të sigurohemi që një gabim i tillë të mos ndodhë në të ardhmen. The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future.
Hi, On Tue, Dec 14, 2021 at 03:03:05PM +0100, Albanian Hosting SH.P.K. via address-policy-wg wrote:
Very interesting! Good catch. And thank you for the information provided, i personally believe that there is no help as because nobody cares at least not the RIPE NCC itself. I do believe that we all are wasting our time here, as long as my small company need a /22 allocation and cannot get it, it's worthless. We are renting them from others in order to survive!
If you have read this thread, you might have noticed that people *do* care. It's just not very clear what can be done, at this point in time, which will have a positive effect. There's lots of things that can be done that have negative effects (like, etra bureaucracy, which increases costs, which then leads to complaints about, well, bureaucracy) but have very little effect on the problem statement: networks getting "more than one /24" for the same entity. The problem statement is not as clear cut as it might seem... if a parent company opens a new subsidiary in every european country, which has their own network, budget, CEO... shouldn't they be entitled to have a LIR account and a /24 for each subsidiary? ... and, of course, it's not like we haven't been telling people since 15+ years that IPv4 is going to run out, and they should use IPv6. Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279
Le Thu, Dec 16, 2021 at 07:46:18PM +0100, Gert Doering a écrit :
... and, of course, it's not like we haven't been telling people since 15+ years that IPv4 is going to run out, and they should use IPv6.
I find this sentence unfair for all of us who deploy IPv6 but still need to support IPv4 because of big players with millions of IPv4 lagging behind. -- Denis Fondras / Liopen
Hi, On Thu, Dec 16, 2021 at 08:26:46PM +0100, Denis Fondras - Liopen wrote:
Le Thu, Dec 16, 2021 at 07:46:18PM +0100, Gert Doering a écrit :
... and, of course, it's not like we haven't been telling people since 15+ years that IPv4 is going to run out, and they should use IPv6.
I find this sentence unfair for all of us who deploy IPv6 but still need to support IPv4 because of big players with millions of IPv4 lagging behind.
Yes, sorry. I did not want to come across as "this is all your own fault", more like "we knew this mess was coming, but failed to handle it in time, as an Industry". But whatever it is, even if some people try hard, we can't create the necessary amount of extra IPv4 space. Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279
Hello Denis, Thank you for your questions. Allow me to answer as many as I can right now. As you indicated, getting the data for some of the requests in your email from 9 December would require quite some time and effort. Considering that Registry Services is currently in the busiest time of the year, I would prefer to first identify if this data would really be beneficial for the ongoing discussion about the IPv4 waiting list policy and potential policy proposal. For example, you asked if some members with 10+ LIR accounts are brokers or are from a certain country. What I can say is that these members are quite diverse. They are located in several countries inside and outside of our service region. Some of these 98 organisations only became members in the last two years, while others opened multiple LIR accounts in the past several years and so received multiple /22 IPv4 allocations under the former "Last /8” policy, and later /24 IPv4 allocations under the current policy. Those members received around 1,100 /22s between September 2012 and November 2019, when the "Last /8" policy was in place. As for your comments about consolidations, I would like to clarify that the RIPE NCC uses this term when a member consolidates some of their LIR accounts into another LIR account. When an LIR receives resources that are restricted by a holding period, those resources must be kept in that LIR account until the holding period has passed. After that 24-month period, these members usually decide to consolidate their LIR accounts, including their resources. If a company were to take over one of its child companies, this would be processed by the RIPE NCC as a merger of two different legal bodies. To provide some more numbers, besides the 98 members that hold 10 or more accounts, we currently have 112 members that hold between 5 and 9 LIR accounts. The maximum amount of /24 allocations that a single member has received under the current policy is 33. So far, no allocations received under the current waiting list policy have been transferred due to the fact that the first such allocation was provided around 24 months ago and almost all allocations are still within their holding period. I hope this answers most of your questions. Kind regards, Marco Schmidt Assistant Manager Registry Services RIPE NCC On 14/12/2021 14:20, denis walker wrote:
Hi Guys
I have some more questions now as I dig deeper into these allocations. Marco mentioned in his email that the situation is quite fluid because of consolidations, transfers, and opening of new LIR accounts that occur all the time. I have found the transfer information, where can I find details of consolidations? Also is the waiting list published anywhere? I have seen companies with say 25 LIRs where 22 have already received a /24 this year. I would like to know if the other 3 LIRs are on the waiting list and at what position.
Now I have some detailed questions about what is meant by consolidation. I will illustrate with an anonymous example. For all my analysis I will not identify any company by name. My intention is to expose behaviour.
So we have a parent company ABC Networks BV. They set up 5 child companies. One in 2017 and 4 in early 2019. One of them is XYZ Networks BV.
XYZ networks BV opens 12 LIRs. Throughout 2019 each of these LIRs receive a /22 allocation. In December 2019 all these LIRs/allocations moved to the parent company ABC Networks BV and the child company XYZ Networks BV was deregistered according to the Chamber of Commerce.
In total the 5 child companies opened 50 LIRs. They each received a /22 throughout 2019 and all these child companies were deregistered in December 2019 with their LIRs/allocations 'transferred' to the parent company. Is this what is meant by consolidation? Not sure what the business case is to register several companies who open several LIRs each to get allocations, then close the companies a few months later and merge all the resources into the parent company...unless it is to try to hide the true number of LIRs the parent company has set up.
The timing is also interesting. All of these child companies were merged with the parent company on 2 December 2019, according to the Chamber of Commerce: "Merger deed passed on 02-12-2019. Acquiring legal entity: ABC Networks BV Disappearing legal entities: XYZ Networks BV..." The child companies were then all deregistered on 5 December 2019, according to the Chamber of Commerce: "As of 5-12-2019, the legal entity has been deregistered due to Termination of registration"
According to the Transfer Statistics the date of the transfer of the resources was 23 December 2019 from the child company XYZ Networks BV to the parent company ABC Networks BV. The ORGANISATION objects in the RIPE Database were also modified on 23 December 2019 to change the "org-name:" to that of the parent company ABC Networks BV. But the child company XYZ Networks BV did not exist on 23 December 2019. So was this a valid transfer? This applies to all 50 of the allocated resources to these child companies's LIRs.
I suspect that when the merger took place on 2 December 2019 the parent company took legal ownership of the assets of the child company, including the LIR accounts with the allocated resources. That means the transfer actually took place on 2 December 2019, not the 23 December 2019 as stated in the Transfer Statistics. That makes the Transfer Statistics wrong. If this is meant to be a legal document that is not good. Something needs to be tightened up here. Maybe it is a chicken & egg situation. The merger has to legally occur and documents supplied to the RIPE NCC before the transfer can be acknowledged. But then the transfer stats should make it clear the transfer actually took place on 2 December when the merger occurred, not the date it was acknowledged by the RIE NCC on 23 December.
It is also not clear to me what has actually been transferred/acquired? Is it the allocations or the LIR accounts with the allocations? In the delegated stats there still exists several entries for nl.xyz1, nl.xyz2, etc. These all refer to the legal name of the parent company ABC Networks BV. Does this mean the parent company has taken control (acquired) all 50 of these LIR accounts with their allocations, not just the allocations? Is this still a consolidation?
Another general question. When a whole resource is transferred (within RIPE region) it looks like the RIPE NCC deletes and recreates the allocation object in the RIPE Database with 'todays' date as the creation date. But the entry in the delegated stats keeps the original allocation date. Is this how it is meant to be documented? (A good example of why a historical query in the RIPE Database should show the full history.)
None of this is explained very well, or at all, in the policies or documentation. It assumes people know a lot more about this registration stuff than a database expert does (but I am learning). If someone can answer these points it may well help some of the new LIRs as well. I am sure there is a steep learning curve here for the newbies.
cheers denis co-chair DB-WG
On Mon, 13 Dec 2021 at 17:17, Albanian Hosting SH.P.K. via address-policy-wg <address-policy-wg@ripe.net> wrote:
Hey Denis Walker,
in 2019 until the end of december the last /22 allocation was assigned to the members/Lirs, once the ripe stopped assigning /22, there was not that much interest in 2020 for only a /24 subnet. And no, it was not free! Since in 2021 the price per IP skyrocketed, and ripe announced that they are out of stock, due because of this and due because the price per IP is going to the moon, the LIRs (mostly big boys) with multiple allocations started to apply for more and believe me they are making a good profit from this. For now is 200€/month is the price for /24 subnet to rent out, and it will be higher and higher.
Cheers.
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Hi Marco & APWG colleagues Thanks for the response Marco. Some of my questions below suggest there may be problems with the Transfer Stats and IPv4 Allocation Policy. These questions are not really for the RIPE NCC to answer, except where there are legal implications, but for this WG to consider... On Thu, 16 Dec 2021 at 16:57, Marco Schmidt <mschmidt@ripe.net> wrote:
Hello Denis,
Thank you for your questions. Allow me to answer as many as I can right now. As you indicated, getting the data for some of the requests in your email from 9 December would require quite some time and effort. Considering that Registry Services is currently in the busiest time of the year, I would prefer to first identify if this data would really be beneficial for the ongoing discussion about the IPv4 waiting list policy and potential policy proposal.
It was only for background information and isn't likely to change the discussion very much. So if you are very busy don't worry about those numbers. My own analysis is likely to be far more explosive. I am still working on the details...
As for your comments about consolidations, I would like to clarify that the RIPE NCC uses this term when a member consolidates some of their LIR accounts into another LIR account. When an LIR receives resources that are restricted by a holding period, those resources must be kept in that LIR account until the holding period has passed. After that 24-month period, these members usually decide to consolidate their LIR accounts, including their resources. If a company were to take over one of its child companies, this would be processed by the RIPE NCC as a merger of two different legal bodies.
So in a merger/acquisition two legal entities, each with one LIR account, becomes one legal entity with two LIR accounts. A consolidation is when one legal entity has two LIR accounts and closes one of those LIR accounts, transfering it's resources to the remaining LIR account. Is that correct? When a legal entity opens two LIR accounts does the legal entity become two legally distinct RIPE NCC members? With a consolidation, is the 'movement' of a resource from the closed LIR to another LIR operated by the same legal entity considered as a transfer? According to section 2.0 of the Transfer Policy the movement of an allocated resource from one RIPE NCC member to another RIPE NCC member is a transfer. So it looks to me that a consolidation IS a transfer and therefore SHOULD be documented in the Transfer Stats? But I don't see any transfers listed as CONSOLIDATION. Why not? In the IPv4 Allocation Policy (ripe-733), section '3.0 Goals of the Internet Registry System', point 3 says: "Fairness: Public IPv4 address space must be fairly distributed to the End Users operating networks." Given the controversy over companies setting up multiple LIRs to (un)fairly acquire the last bits of IPv4 addresses available through the RIPE NCC being discussed in this thread, in the interests of fairness, as well as openness and transparency, should consolidation 'transfers' be included in the Transfer Stats? With the current /24 allocation policy there is a condition that these allocations cannot be transferred for at least 24 months. Are there any conditions/expectations on who can use this address space or who can administratively and technically control these addresses? Is it acceptable that within these 24 months, a separate legal entity takes over both administrative and technical control of this allocated address space and manages the assignment of it? So the legal entity that received the allocation is just a 'shell' that exists only to satisfy the 24 month no transfer condition. Now I want to ask a very specific legal question. In the Transfer Policy, section '2.1 Transfer Requirements' says: "The original resource holder remains responsible for an Internet number resource until the transfer to the receiving party is completed." So in the example I gave earlier, Company ABC acquired company XYZ (and presumably all it's assets including the LIR it operated) on 2 December. According to the Chamber of Commerce, company XYZ was deregistered on 5 December. So it no longer existed as a legal entity after 5 December. The Transfer Stats state the transfer of the resources from XYZ to ABC occured on 23 December. According to the Transfer Policy section '4.0 Transfer Statistics' says the published date is "The date each resource was transferred". So who was legally responsible for those IP resources between 5 and 23 December? cheers denis co-chair DB-WG
participants (8)
-
Albanian Hosting SH.P.K. -
Denis Fondras - Liopen -
denis walker -
Florian Fuessl -
Gert Doering -
Marco Schmidt -
Mathias Westerlund -
Mike Bromwich