[arin-ppml] Policy Question(s)

Tue Oct 5 13:04:28 EDT 2010

The guy has a good point, so arin get your docs out and answer him.  

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--- On Tue, 10/5/10, Scott Leibrand <scottleibrand at gmail.com> wrote:

> From: Scott Leibrand <scottleibrand at gmail.com>
> Subject: Re: [arin-ppml] Policy Question(s)
> To: "'Ronald F. Guilmette'" <rfg at tristatelogic.com>, arin-ppml at arin.net
> Date: Tuesday, October 5, 2010, 7:34 AM
> Ronald,
> 
> It sounds like you've got a fairly good handle on the
> policy.  As I think
> you mentioned, the operative policy is in section 8:
> https://www.arin.net/policy/nrpm.html#eight
> 
> 8.2 covers transfers due to Mergers and Acquisitions, which
> is traditionally
> the policy applied to situations like this.  It
> requires that "the new
> entity has acquired assets that used the transferred
> resources from the
> current registrant", and that the addresses remain
> justified under current
> ARIN policy.
> 
> It's also possible to transfer IPv4 addresses using 8.3,
> which doesn't
> require M&A, but must be "received under RSA by
> organizations that are
> within the ARIN region and can demonstrate the need for
> such resources, as a
> single aggregate, in the exact amount which they can
> justify under current
> ARIN policies."
> 
> If you have information to indicate that company C does not
> have justified
> need for the /18 under current policy (and/or didn't at the
> time they became
> the registrant in ARIN's database), please do provide your
> information to
> ARIN (https://www.arin.net/resources/fraud/) so
> they can investigate.  The
> information they received at the time of the transfer is
> confidential, but
> they can take your tip, investigate, and institute a
> section 12 Resource
> Review (https://www.arin.net/policy/nrpm.html#twelve) if
> justified.
> 
> It might also be worth noting that there is a policy
> proposal on the docket
> this week in Atlanta to require ARIN to institute resource
> reviews under
> various circumstances, including "Upon receipt by ARIN of
> one or more
> credible reports of fraud":
> https://www.arin.net/policy/proposals/2010_11.html 
> If you have an opinion
> on whether that would be good policy, I would encourage you
> to participate
> in the meeting discussion, either in person or remotely:
> https://www.arin.net/participate/meetings/ARIN-XXVI/remote.html
> 
> Thanks,
> Scott
> 
> -----Original Message-----
> From: arin-ppml-bounces at arin.net
> [mailto:arin-ppml-bounces at arin.net]
> On
> Behalf Of Ronald F. Guilmette
> Sent: Tuesday, October 05, 2010 5:23 AM
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Policy Question(s)
> 
> 
> In message
> <0F29D1BA57992E4CAB5AD2C9AE7B42393777FABA at EMV01-UKBR.domain1.systemh
> ost.net>, michael.dillon at bt.com
> wrote:
> 
> >> >    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?
> >
> >Companies often divest part of their operations to
> another company.
> >Sometimes they just sell network assets which would
> include a functioning
> >network and its IP addresses and customers.
> 
> I'm sorry. I wasn't clear.  I left out some important
> details.
> 
> As far as I can tell there was no transfer of customers,
> nor of any
> networking
> hardware, not of any ``hosts''.  Just the IP space.
> 
> Now, is _this_ scenario considered usual & customary?
> 
> Is it considered acceptable, under current policy?
> 
> >The receiving company generally has its own network and
> integrates the
> >two networks, reusing the old addresses on the
> integrated network before
> >decommissioning the purchased one.
> 
> Again, I may not have been clear.  The ``receiving''
> company (C) in this
> case
> was only born in October of last year.  It had no
> network of its own prior
> to that, nor any customers, prior to that, nor any IP
> addresses, prior to
> that.
> As far as I can tell, all it ever has had was the /18 it
> was given (as a
> birthday gift?) by Company B.
> 
> So now, as I have clarified it, is _this_ scenario
> considered usual &
> customary?
> 
> Is it considered acceptable, under current policy?
> 
> >Truth is stranger than fiction which means that a lot
> of oddities are
> >perfectly normal.
> 
> Yes, however this one is looking like a Greek god...
> 
>   ``Athena leaped from Zeus's head, fully grown and
> armed -- with a
> shout...''
> 
> Company C only came into being in October of last year, and
> yet
> presto-changeo!
> It seems to have been born fully formed, like Athena, with
> its own /18
> (which,
> it would seem, may never have been justified or audited in
> any way, despite
> its being non-legacy space).
> 
> (Remember, this is _not_ ``legacy'' space we are talking
> about.  The /18 in
> question was first allocated... presumaby by ARIN, under an
> RSA... in July,
> 1999.)
> 
> So my question remains... if _someone_ creates a brand new,
> fresh, newly
> manufactured LLC, can some other company that happens to
> have an unused
> /18 lying around just ``gift'' that /18 to this new legal
> entity the
> very next day?
> 
> And if that does happen, shouldn't ARIN balk at putting the
> new entity's
> name into the WHOIS record as the new legal ``owner'' of
> the block?
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