ARIN legacy block transfer process

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1

I'm trying to find a place on ARIN's website where this is addressed, but
coming up short. I'm not the seller or buyer in this, but basically someone
has a legacy block allocated by Postel and wants to sell the block as it's an
owned asset.

What's the process to get ARIN to move the admin/ownership of this? Do they
only need to see a valid asset purchase agreement? There is no legacy RSA for
this.

I'm thinking of referring both parties to an experienced broker as well.

Does anyone have current process experience with this?

2

I would review this:

https://ripe72.ripe.net/presentations/65-160524.ripe-transfer.pdf

- Jared

3

Hi Bryan,

If this is entirely within the ARIN region, the process is this:

1. Buyer gets approved by ARIN for a specified transfer in the amount
to be purchased. Signs RSA.
2. Legacy registrant (seller) signs the LRSA, proves identity and
authority to ARIN, places legacy block under the LRSA.
3. Buyer requests specified transfer from ARIN, seller authorizes it.
4. ARIN transfers registration to buyer, now under the RSA.

Note that you can't sell the block as an "owned asset" and have ARIN
recognize the change. ARIN does not recognize ownership of IP address
blocks, they only recognize registration and authorized agents.

Note that if the legacy block's registration is defective, you're in
for some trouble. Defects include a defunct organization where an
individual who is not the registrant has maintained the block.

Regards,
Bill Herrin

4

It'll have to go under RSA to stay with ARIN.

Or you can do a transfer to RIPE.

~Seth

5

This would seem to be in violation of what the NSF has said about this space.
I thought ARIN was slapped hard once before about this very thing?

Thanks,

6

1. Buyer gets approved by ARIN for a specified transfer in the amount
to be purchased. Signs RSA.
2. Legacy registrant (seller) signs the LRSA, proves identity and
authority to ARIN, places legacy block under the LRSA.

i don't recall having to sign an LRSA, but they certainly do need proof that
you are the entity that holds the block.

3. Buyer requests specified transfer from ARIN, seller authorizes it.
4. ARIN transfers registration to buyer, now under the RSA.

if you are a legacy holder, and you want a dead simple way to sell off your
rights to blocks, register for the STLS, and get your blocks added to the
list.
https://www.arin.net/public/secure/downloads/index.xhtml
(at the bottom)

this is also a good place to go if you want to buy rights to a block.

you can also solicit offers to buy from anyone on the list.

works well, and less dodgy-ness, since everyone on the list has been
vetted (to some degree) by ARIN.

--jim

7

Hi,

> I'm trying to find a place on ARIN's website where this is addressed, but
> coming up short. I'm not the seller or buyer in this, but basically someone
> has a legacy block allocated by Postel and wants to sell the block as it's an
> owned asset.
>
> What's the process to get ARIN to move the admin/ownership of this? Do they
> only need to see a valid asset purchase agreement? There is no legacy RSA for
> this.

It'll have to go under RSA to stay with ARIN.

Or you can do a transfer to RIPE.

carefully note the "or".
If you first move it under ARIN's jurisdiction (by signing an RSA) and *then* transfer it to RIPE, it won't be "legacy" any more in the course of the 2nd step and RIPE's 2-yr holding period comes into play (=> it can't be transferred during that time).

Note also there's voices recommending not to sign an RSA for legacy space (in certain situations, at least), see Don’t sign an RSA during 8.2 IPv4 Transfer | IPv4 Market Group.

best

Enno

8

Hi Enno,

The article says:

"Never sign an RSA as part of bringing your registry entry up to date,
unless you are in the process of a transfer for an IPv4 sale"

I agree with that statement. But, the situation here *IS* a transfer
for an IPv4 sale. If you want to do the transfer, the originating
registration has to be under a registration services agreement (RSA).
As a legacy registrant, the LRSA is slightly more advantageous than
the regular RSA.

If the legacy registrant is actually in Europe, you might get away
with bypassing ARIN. I wouldn't try it if they aren't.

Regards,
Bill Herrin

9

To the best of my knowledge, that's not the case. Every relevant court
case has ended one of two ways:

1. The addresses were revoked after the POC was (correctly) determined
not currently represent the (defunct) registrant.
2. The registrant consented to place the addresses under an ARIN RSA
without a judicial ruling. (e.g. Microsoft/Nortel)

Regards,
Bill Herrin

10

But only the recipient must put them under an RSA in order to have them
registered. The source need not have an RSA or LRSA for their legacy
blocks, at least as I understand it.

I'd also suggest that having a broker is useful, because the few well-known
ones that exist are well-versed in the process by now, for all types of
sources and destinations.

Matthew Kaufman

11

I'm trying to find a place on ARIN's website where this is addressed, but
coming up short. I'm not the seller or buyer in this, but basically someone
has a legacy block allocated by Postel and wants to sell the block as it's an
owned asset.

What's the process to get ARIN to move the admin/ownership of this? Do they
only need to see a valid asset purchase agreement? There is no legacy RSA for
this.

Bryan -

It is not required (but if they were presently under LRSA, then the transfer would
indeed be faster since the organization and IP address block would not have to
be revalidated…)

I'm thinking of referring both parties to an experienced broker as well.

That certainly works - there is a list of several brokers available here
<https://www.arin.net/resources/transfer_listing/facilitator_list.html&gt;
and many of them are very experienced in facilitating transfers under
a wide variety of circumstances.

Does anyone have current process experience with this?

Yes, I seem to have some experience with these processes…

The legacy resource holder has to be validated by ARIN. This can be
accomplished by simply making sure that the seller is a point-of-contact
on the organization which hold rights to the IP address block (and is
smart thing to do in any case, since they can then update the contacts,
correct reverse DNS servers, etc.)

You can have the source (i.e. the legacy resource holder) contact ARIN’s
hostmaster (Hostmaster Arin <hostmaster@arin.net>), or have them call us
Monday through Friday, 7:00 AM to 7:00 PM ET, Phone: +1.703.227.0660
and we’ll walk them through the organization recovery process.

Once the legacy holder has control of the organization and IP address block,
they can submit a transfer ticket at any time. ARIN will seek documentation
behind the transfer, and will confirm that the recipient is valid. For a recipient
in another region, we seek concurrence from the serving RIR that the recipient
is valid.

If you need any additional assistance, feel free to reach out to myself or
the ARIN registration services helpdesk.

Thanks,
/John

John Curran
President and CEO
ARIN

p.s. Apologies for the delay in getting you this response - it has been a bit hectic
       these last 48 hours...

12

Probably best to talk to a variety of IP brokers (including the one
publishing the above blog) for more current information, as this
has been a fairly rapidly changing area and the referenced blog
contains both inaccuracies and statements that lack context.

For example, there is a suggestion not to undertake a “NRPM
8.2 Merger and Acquisition IPV4 transfer” due to the need to
sign an RSA in the process. The advice may be applicable to
some who are adverse to the RSA, but is specifically about only
one type of transfer, i.e. transfer via merger and acquisition, not
an specified IP address block sale as most people consider…

Another example is the assertion that "ARIN says it will then not
allow transfers from ARIN to RIPE, once inter-RIR transfers are
allowed by RIPE, because there is no “like” needs based policy.”
While that might have been correct at one point in time, RIPE
did adopt a rather generous needs-based policy that is indeed
compatible with ARIN’s inter-RIR transfer policy, and we’ve done
many transfers to the RIPE region since that time.

The combination of inaccuracies and outdated information dilute
the value of historical blog posts, so caveat emptor when revisiting
such…

FYI,
/John

John Curran
President and CEO
ARIN

13

1. Buyer gets approved by ARIN for a specified transfer in the amount
to be purchased. Signs RSA.
2. Legacy registrant (seller) signs the LRSA, proves identity and
authority to ARIN, places legacy block under the LRSA.

i don't recall having to sign an LRSA, but they certainly do need proof that
you are the entity that holds the block.

That’s correct Jim.

3. Buyer requests specified transfer from ARIN, seller authorizes it.
4. ARIN transfers registration to buyer, now under the RSA.

if you are a legacy holder, and you want a dead simple way to sell off your
rights to blocks, register for the STLS, and get your blocks added to the
list.
ARIN - American Registry for Internet Numbers
(at the bottom)

this is also a good place to go if you want to buy rights to a block.

you can also solicit offers to buy from anyone on the list.

Also correct - ARIN runs the Specified Transfer Listing Service (STLS) so
that parties that wish to be vetted by ARIN may do so in advance, and also
optionally be listed as “interested in offers” from others using the STLS service.
Also, potential recipients may have their IP address need verified in advance,
therefore making them a qualified recipient in the ARIN region. It’s completely
optional, but available for those who wish to validate their half of a transfer
(whether as a source or recipient) in advance.

works well, and less dodgy-ness, since everyone on the list has been
vetted (to some degree) by ARIN.

I’m glad you like the STLS service; it does work well for straightforward
transfers among parties. There are some cases (complex corporate
changes, long absent or incorrect registration information, etc.) where
parties may find the support and guidance of one of the brokers helpful;
it doesn’t matter to ARIN either way nor does it change the criteria that
we apply - all transfers follow the same policy.

Thanks!
/John

John Curran
President and CEO
ARIN

14

NSF’s Chief Counsel provided his views on the matter, but had to subsequently
clarify that his views were based on NSF’s historic role and noted that he did not
speak for the USG on such matters (as they were now properly within the remit
of the US Department of Commerce/NTIA… oops!) -
<https://www.arin.net/resources/legacy/NSF-Rudolph-ARIN-7NOV2012.pdf>

The agency with actual authority in these matters (NTIA) subsequently issued a
statement of the the US Government’s Internet Protocol Numbering Principles,
which noted that “the American Registry for Internet Numbers (ARIN) is the RIR
for Canada, many Caribbean and North Atlantic islands, and the United States
and furthermore that the USG “participates in the development of and is supportive
of the policies, processes, and procedures agreed upon by the Internet technical
community through ARIN.”
<http://www.ntia.doc.gov/blog/2012/united-states-government-s-internet-protocol-numbering-principles>

i.e. ARIN continues to enforce the community-developed policies on all resources
in the registry, and including legal undertakings where necessary to that end.

FYI,
/John

John Curran
President and CEO
ARIN

p.s. Note that all organizations may use ARIN Online to update their ARIN IP number
       resource records. Organizations that received number resources directly from
       ARIN have ARIN Online access via their Registration Services Agreement.
       For organizations that received resources before ARIN’s formation in December
       1997 (i.e. “Legacy Resource Holders”), ARIN has been providing, without any
       fee or registration services agreement, access to ARIN Online as well as the
       basic IP registration services in place at the time of ARIN’s formation; this does
       include the ability to submit tickets to transfer an IP address block to another party.

       Legacy Resource Holder organizations that wish to receive these basic registration
       services under a formal agreement, or wish to utilize additional services (such as
       resource certification, i.e. RPKI), and/or desire a written statement of their rights to
       their IP number resources must enter into a Registration Services Agreement.

15

[ clip ]

I'm thinking of referring both parties to an experienced broker as well.

That certainly works - there is a list of several brokers available here
<https://www.arin.net/resources/transfer_listing/facilitator_list.html&gt;
and many of them are very experienced in facilitating transfers under
a wide variety of circumstances.

Morning NANOG'ers;

Disclaimer: Get IPv6. Deploy it. Avoid cost. With that said...

The theme of the thread is that brokers can be useful. I'd argue they
are almost imperative for those wishing to be completely informed. I'm
not criticizing, but I'd be careful to understand that along with
using the STLS (as well as making transfers) comes additional
sacrifice of rights and assumption of liabilities.

      Specified Transfer Listing Service (STLS) - American Registry for Internet Numbers

That list also missing at least one significant company:

     ADDREX http://www.addrex.net/ -

My personal list of go-to brokers is for questions like asset
disposition, acquisition, transfers and the conversation above
(alphabetically):

Addrex
Hilco
IP Trading

Hope this is helpful.

YMMV, and best,

-M<

16

...
Disclaimer: Get IPv6. Deploy it. Avoid cost. With that said…

Indeed: we are likely to have a rather convoluted market supply curve for
IPv4 blocks over the next decade, and those dependent on IPv4 as their
primary means of network growth will have unpredictable costs as a result.

The theme of the thread is that brokers can be useful. I'd argue they
are almost imperative for those wishing to be completely informed. I'm
not criticizing, but I'd be careful to understand that along with
using the STLS (as well as making transfers) comes additional
sacrifice of rights and assumption of liabilities.

Marty -

100% agreement… while I am quite willing to explain to folks what I believe
makes sense for them regarding transfers, I ultimately must represent the best
options with respect to delivery of ARIN’s mission to the community. A broker
(and/or informed legal counsel) can provide a view which is solely focused on
the address holder’s interests – while this may often lead to the same outcome,
that is not assured in all cases.

Thanks,
/John

John Curran
President and CEO
ARIN

17

The agency with actual authority in these matters (NTIA)

inappropriate use of present tense

18

fwiw, i did a transfer with the source in arin. i found arin's folk
very very helpful, and the process navigable, even for someone who is
administratively impaired such as i. ignore the political positioning,
plan ahead, be sure of all your options at each fork in the road, and
proceed with caution. if this space is strange to you, recommendations
of using a broker or lawyer who has trod the path are apt.

randy

19

Yes, Randy - excellent point.

I should have included "at the time" in that sentence...

Thanks!
/John

20

yep, i agree.

i recently was the source of a pile of transfers from /24's to a /16,
both inside ARIN, as well as a couple out of ARIN into RIPE.

also did some with brokers (iptrading.com), as well as direct deals.

as long as all the documentation is straight, the process seems to move along
cleanly.

--jim