[arin-ppml] ARIN-PPML Digest, Vol 70, Issue 141

John Curran jcurran at arin.net
Fri Apr 29 10:54:51 EDT 2011

On Apr 29, 2011, at 10:28 AM, Mike Burns wrote:

And if the deal was per policy, as you say, can we make the assumption that it is entirely within ARIN policy for legacy IP addresses to transfer as a result of mergers and acquistions without any notice to ARIN?

Mike -

   ARIN does recognize M&A mergers under the policies that were applicable
   the time of the merger.  Prior to May 2010, this means that an organization
   that acquires substantially all of the the operations of another organization
   would result in the transfer of the resources per NRPM 8.2.   We often have
   to perform such updating of registration records when an organization that
   hasn't been maintaining records comes to ARIN for the first time.  (Note that
   demonstrated need applies to transfers for M&A's after May 2010 due to the
   revision of the NRPM 8.2 which occurred at that time)

   With respect to the single aggregate, please refer to the attached email to
   ppml.  As it is, the phrase applies to the assessment of need as opposed
   to the transferred number resources.


John Curran
President and CEO

Begin forwarded message:

From: John Curran <jcurran at arin.net<mailto:jcurran at arin.net>>
Date: April 18, 2011 9:49:42 PM EDT
To: Benson Schliesser <bensons at queuefull.net<mailto:bensons at queuefull.net>>
Cc: ARIN-PPML List <arin-ppml at arin.net<mailto:arin-ppml at arin.net>>
Subject: [arin-ppml] Implementation of NRPM 8.3

On Apr 18, 2011, at 8:57 PM, Benson Schliesser wrote:

Thanks for clarifying.  Combining this with your other recent messages, here is what I conclude about ARIN's implementation of NRPM 8.3:

1) ARIN will accept any legally enforceable document confirming ownership and the desire to transfer.

ARIN requires the seller to attest to being the valid address holder and
that they desire to transfer to the recipient.

2) ARIN will accept any form of RSA with the buyer, including the standard LRSA or a negotiated LRSA, and the actual agreement language will be kept private without disclosure to the ARIN membership or community.

Not quite. The resources transferred must come under a registration services
agreement; this will usually be a standard RSA, unless otherwise required by
nature of the transfer.  If legacy resources are involved, the result could
be an LRSA, just as can occur during the assignment of an LRSA during an 8.2
M&A transfer.

3) ARIN will accept justification of need from buyers, in private and without disclosure to the ARIN membership or community.


4) ARIN will accept the transfer of any arbitrary collection of address blocks, as long as the total is in compliance with justified need.

ARIN has to implement NRPM 8.3 as written, and while it does not
support "any arbitrary collection of address blocks", the existing
existing NRPM 8.3 language may be less than ideal when compared to
some goals in the rational of the policy. At the San Juan PPM, the
Policy Experience report noted that there was nothing to prevent
transfers of resources received back out of the receiving organization,
and similarly it does not appear to preclude multiple successive
transfers (depending on the particular utilization situation).
The above issues are compounded by the "single-aggregate" language
applying to the demonstrated need as the policy is presently written.

While I've mentioned some of these issues individually, I appreciate
your question and the opportunity to put these all in one place as
it may help folks in determining possible next steps for refinement
of the policy.


John Curran
President and CEO

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