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

Mike Burns mike at nationwideinc.com
Fri Apr 29 11:08:47 EDT 2011

Torture the language any way you wish, call it "less than ideal", imagine conforming to it through a succession of transfers, claim it only applies to the need assessment. I leave it to the community to decide the meaning of this short paragraph:

In addition to transfers under section 8.2, IPv4 number resources within the ARIN region may be released to ARIN by the authorized resource holder, in whole or in part, for transfer to another specified organizational recipient. Such transferred number resources may only 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.

You ignore the requirement to return the resources to ARIN, you claim "received as a single aggregate" to mean something other than that, and you break ground in considering an LRSA an RSA.

I remain unconvinced, and I note that you wish us to continue to believe that the arbitrary assortment of addresses which Microsoft contracted to buy from Nortel prior to ARIN's involvement in the deal turned out to be the exact amount required in the ex post facto needs analysis of the deal.



  ----- Original Message ----- 
  From: John Curran 
  To: Mike Burns ; Mike Burns 
  Cc: Rudolph Daniel ; arin-ppml at arin.net List 
  Sent: Friday, April 29, 2011 10:54 AM
  Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 70, Issue 141

  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>

    Date: April 18, 2011 9:49:42 PM EDT

    To: Benson Schliesser <bensons at queuefull.net>

    Cc: ARIN-PPML List <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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