[arin-ppml] Policy Question(s)
Ronald F. Guilmette
rfg at tristatelogic.com
Mon Oct 4 14:37:31 EDT 2010
In message <10013.1286197958 at marajade.sandelman.ca>,
Michael Richardson <mcr at sandelman.ca> wrote:
>>>>>> "Ronald" == Ronald F Guilmette <rfg at tristatelogic.com> writes:
> Ronald> Company B still exists. It has an active web site and it is
> Ronald> taking orders for T1 lines. The grand total of all IP
> Ronald> address space that Company B ever had, even in its heyday,
> Ronald> was the /18, and a tiny little /29, which was obtained out
> Ronald> of the allocation of another provider. Because of the early
> Ronald> date of /18 allocation, and the chain of inheritance, my
> Ronald> guess is that most probably, Company B never had to
> Ronald> ``justify'' their use of the /18 at all, ever. (Is that
> Ronald> correct?)
> Ronald> Fast forward to October of last year, 2009. In that month,
> Ronald> a brand new Limited Liability Company (LLC) was formed in
> Ronald> the same state as Companies A and B. Let's call this
> Ronald> `Company C'. The mailing address for Company C is the same
> Ronald> as that for Company B.
> Ronald> Now, fast forward to today. Right now, today, ARIN records
> Ronald> show the /18 to be registered to Company C.
>Company B still exists, I think? Does it still do business?
>Does it still have T1 customers?
Yes, yes, and yes.
> Ronald> Would it ever have been permissible for Company B to sell,
> Ronald> to ``gift'', or to in any other way transfer, just late last
> Ronald> year, its /18 to this brand new LLC, Company C?
>It could certainly assign address space from B->C, just like it would
>any other chunk. Can it assign the entire /18, I don't know. If it did
>that, whois would still show company B in the chain.
And what if it doesn't? See that's what I'm asking about. Now, the WHOIS
record for the whole original /18 only shows Comapny C as the ``owner''.
> Ronald> Does it make any difference that Company B and Company C
> Ronald> seem to be in some sense ``sister'' companies, perhaps with
> Ronald> a significant overlap of management and/or ownership?
>Yes, because it makes it much more likely to explain that Company C acquired
>Company B, and that Company B is really a wholy-owned subsidiary.
And what if that is NOT the case?
If Company C _did not_ wholly aquire Company B, but still, somehow, as of
now, it is only Company C's name on the WHOIS for the /18, then does this
indicate that something has happened, somewhere along the line, that
violated, or went against current policy?
See that's what I'm getting at. May an older company (B) which has NOT
been bought out, and which is still actively in business simply ``gift''
a /18 that it happens to have lying around to a freshly-minted new company
(C) such that we wake up one day and it is only Company C's name on the
Frankly, this doesn't seem right.
> Ronald> I guess my question is: Can a brand new company, with no
> Ronald> history whatsoever, file papers with the state, to become a
> Ronald> legit, LLC, and then waltz in to ARIN the very next day and
> Ronald> get themselves a whole fresh new /18 ? Can they do it if
>yes, there are ways they could do that: having some kind of construction
>contract inked and signed for some kind of network build that would be
>completed within 30 days, and would use an entire allocation.
OK. I think I understand. May I safely assume that if such documents
existed, and if they had been submitted... you know... to ARIN... as part
of justifying the assignment/aquisition of a /18, that those would be
treated as confidential, and not be in any sense part of the public
And separately, if such documents existed... documents which would justify
Company C's immediate need for a whole /18, then those would be sufficient,
nder existing policy, for ARIN to assign a whole new _fresh_ /18 to the
company for its use, right? So in that case, Company C wouldn't have had
to ``beggar'' Comapny B for _its_ old /18, because it has justification
in hand for a whole _new_ /18, right? So if Company C ended up with
what was (past tense) Company B's old /18 under this scenario, then that
would be rather... ummm... odd, yes?
(Forgive me for continuing to use pseudonyms for the three companies I've
discussed. I just don't want to cast any aspersions on any actual companies
until I understand what is and what isn't conformant to policy. I mean
maybe none of these companies had done anything out of the ordinary at
all, nor anything counter to current policy. I don't know yet, but it
sure all does look mighty odd.)
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