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On Aug 17, 2015, at 8:13 PM, Mike Burns <<a href="mailto:mike@iptrading.com" class="">mike@iptrading.com</a>> wrote:<br class="">
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<div class="">However we do have access to a very few public transactions like the famous Nortel sale of a bunch of blocks, none of which referenced Nortel in Whois. Real, not boogeyman. Because the relevant 8.2 transfers did not happen (ex post facto, they
did).<br class="">
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<div>Mike - </div>
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<div> Your Nortel reference is incorrect, as it is _very_ clear in the case of a bankruptcy </div>
<div> that nothing is transferred until the court approves the order; in the Nortel case,</div>
<div> the court approved a revised sale order only after ARIN reviewed the facts </div>
<div> and concurred. You made a similar errant assertion on the ppml mailing </div>
<div> list on 3 June 2015, and I noted at that time your recollection was off - </div>
<div> <<a href="http://lists.arin.net/pipermail/arin-ppml/2015-June/029988.html" class="">http://lists.arin.net/pipermail/arin-ppml/2015-June/029988.html</a>></div>
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<div> I do believe there is real potential of exactly what you assert is happening, i.e. </div>
<div> there are likely 'shell corporations are being bought and sold for their IPv4 assets </div>
<div> without notice to ARIN’ - it is just your particular cite is almost the opposite case </div>
<div> (where ARIN is formally notified prior to approval and gets quite involved in the</div>
<div> review and approval as a result)</div>
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<div class="">The same thing happens today. We tell clients in these cases where they acquire shell corporations that they are free to apply for an 8.2 transfer if they wish to see the addresses registered in their name. If they don't want to undergo the process,
they have the option of simply relying on their legal documentation of company ownership to verify their ownership rights, and leave the block in the acquired company's name at ARIN.<br class="">
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This proposed version of the RSA would directly affect holders who were acquiring addresses in this way who also held other blocks. What do you think their option will be when you put another obstacle in the way of those might consider bringing some blocks
under RSA?<br class="">
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To be clear, the _present_ RSA and LRSA have the language which you object to, </div>
<div> and the proposed versions change some (but not all) of the general references to</div>
<div> “number resources” to “included number resources.”… i.e. this is an existing </div>
<div> situation which is the proposed RSA fails to address, not a new condition which </div>
<div> would be caused by the proposed RSA.</div>
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<div>Thanks,</div>
<div>/John</div>
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<div>John Curran</div>
<div>President and CEO</div>
<div>ARIN</div>
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