[arin-ppml] Draft Proposal for Needs-Free IPv4 Transfers

[Owen DeLong]

On May 10, 2011, at 3:40 PM, Mike Burns wrote:

>>> The "skipping extra procedural step" sounds a lot like failing to issue the addresses back to ARIN for the designated transfer to MS, ...
> 
> 
> > As noted before, ARIN routinely recognizes M&A mergers after the fact 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 usually have to perform such updating of registration records when an organization
>  >that hasn't been maintaining records comes to ARIN for the first time.
> 
> Hi John,
> 
> I wasn't referring to the ex post facto 8.2 transfers, I was referring to 8.3 requirement to release the addresses to ARIN for subsequent transfer to the directed recipient.
> 
> Which I thought you later said was a procedural issue or similar words.
> There was nothing in the court documents about the addresses being released to ARIN at any point in time.
> 
> My underlying point is the evident struggle to cover seemingly otherwise legal transactions with ARIN policies.
> 
> Just as it is better to reflect 8.2 transfers after-the-fact to comply with policy in order that whois retain accurate information, it would be better if the needs justification was dropped for transfers. Both these things increase the likelihood of valid whois information.
> 
> In the Microsoft case the needs established by ARIN's needs analysis fortunately fit with the volume of addresses Microsoft had negotiated to purchase.
> 
> In the future, this may not be the case, and this may cause the recipient to choose to forego registration of the transfer with ARIN.
> 
At which point if the transferor is no longer using the addresses for their original purpose,
they should be reclaimed by ARIN and reissued to other parties.

Owen