[ppml] Securities Act 15 U.S.C. 77b(a)(1)

John Curran jcurran at istaff.org
Tue Mar 11 13:01:43 EDT 2008

At 4:34 PM +0000 3/11/08, <michael.dillon at bt.com> wrote:
>Many of the people promoting IP address transfers have also spoken in
>favor of a scenario which sounds and awful lot like a securities
>exchange scenario. They hold this forth as a carrot to entice
>supporters. But can they actually deliver all the features of that
>carrot without attracting SEC regulatory oversight? I don't know and I
>don't think that anyone in ARIN, (BoT, staff, AC, members, hangers-on)
>really has the specialist knowledge to make that determination.

Michael -
   It's possible that you didn't see my response below:  We have had
   ARIN Counsel look into this possibility per your request, and it does
   not appear to be an issue.   If a specific policy proposal comes before
   the Board, we will seek an in-depth legal review at that time.

Chair, ARIN Board of Trustees

>To: <michael.dillon at bt.com>
>From: John Curran <jcurran at istaff.org>
>Subject: Re: [ppml] NANOG IPv4 Exhaustion BoF
>Cc: <ppml at arin.net>
>At 8:46 PM +0000 3/4/08, <michael.dillon at bt.com> wrote:
>>So far, from the discussion that I have seen, it does not appear that
>>anyone seriously considered the possibility that the IP address
>>market proposals are getting rather close to the territory that the
>>SEC regulates. That's why I'm raising the issue here, in hopes that
>>some of the people on this list will discuss it with the BoT,
>>and with some sort of legal advisor who has expertise in the right
>>area of law. It could be the current counsel or some other lawyer.
>>That is up to the BoT.
>It has been raised as an issue and discussed.   At first review by our
>counsel, there does not appear to be an issue here.
>The Board will ask for a more formal opinion of the legal ramifications
>(as we always do) if/when a recommendation for new policy comes
>before it.
>Chair, ARIN Board of Trustees

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