[arin-ppml] 2009-1 comment

Kevin Kargel kkargel at polartel.com
Wed May 27 16:26:43 EDT 2009

Thank you for your clarification John.  I completely agree with section 8.2.
We definitely need to facilitate acquisitions.  Even though the combined
resources may be more than the receiving company needs, renumbering a large
network is not going to happen overnight and they will need some unknown
quantity of time to merge the networks.  Hopefully the companies will see
fit to do so, and if not they will likely grow into the excess space and
just not need more allocation so soon.

My problem is the outright sale of space to a designated party without
transfer of network assets and without making the space available to the
community at large as is allowed in 8.3.  This creates an enormous potential
for unfair practice giving the large players a huge advantage.

> -----Original Message-----
> From: John Curran [mailto:jcurran at arin.net]
> Sent: Wednesday, May 27, 2009 3:13 PM
> To: Kevin Kargel
> Cc: arin ppml
> Subject: Re: [arin-ppml] 2009-1 comment
> On May 26, 2009, at 5:17 PM, Kevin Kargel wrote:
> >
> > Being that 2009-1 is listed as under discussion on ppml on
> > https://www.arin.net/policy/proposals/index.html, I want to make
> > another
> > comment.  Section 8-2 is make completely superfluous as any
> > transfers for
> > the purpose of mergers and acquisitions could just as easily be
> > handled
> > under the sell it to anyone you want clauses in section 8-3.
> One nuance that I'd like to bring out for clarity's sake:
> Transfers as a result of mergers and acquisitions go through a
> confirmation step to insure that the actual operational resources
> (i.e. equipment, routers, hosts) are moving along to the new entity.
> This is to insure that we don't have the number resources go one
> direction and the actual network go another.  However, this is
> not, per se, a completion justification of all of the transferred
> number resources and their need.  As long as substantially all
> of the assets are transferred, then transfer of associated number
> resources is allowed. One can imagine various multi-billion dollar
> firms acquiring one another another; a complete rejustification of
> all number resource usage would be very prohibitive, much like
> asking the firm to reapply for all of its building permits,
> operating licenses, etc. on the day of close.
> As such, a transfer due to NRPM 8.2 is significantly different
> that that proposed under 8.3 (where the acquiring entity must
> fully qualify for the resources to be received, just as any
> other application for additional resources).
> I provide this information to help the community in its discussion,
> and not to suggest what the appropriate outcome should be.  We can
> obviously have both 8.2 and 8.3, or harmonize them to one approach
> or other if the community so desires.
> /John
> John Curran
> Acting President and CEO

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