[arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

[John Curran]

On May 11, 2011, at 6:37 PM, Owen DeLong wrote:

> There is no reason that ARIN, upon conducting a section 12 review and finding that the original holder was
> no longer using the resources and/or was defunct could not reclaim those resources, so, the recipient in that
> case is taking a rather large risk. I do not believe ARIN will view the asset sale agreement as legitimizing
> the transfer and the community developed policies support reclamation of resources from defunct legacy
> holders. ARIN has reclaimed such resources in the past, though I do not know if they have reclaimed them
> from organizations who believe they were able to "purchase" them as part of some form of asset transfer.

We have not done so to date (as far as I am aware, and I would
have very likely have been made aware of any action to do so)

We have reclaimed in cases where parties have asserted that 
they have the right to use specific resources due to merger
or acquisition, could not produce any paperwork, and then the 
original address holder turned out to be defunct or denied 
that any transfer was intended.  These cases almost always 
involve recipient parties that then quickly disappear rather 
than further pursue the matter, and similar indications of 
hijack attempts.

While I recognize that ARIN could theoretically reclaim
address space from a defunct legacy address holder where 
the successor organization simply does not wish to update
their records per M&A transfers (NRPM 8.2), that course 
of action appears to me to be more punitive than actually
advancing the mission of the organization.  The record
keeping subsequent to an merger/acquisition often does 
not get cleaned up for several years subsequent to the
actual event, and first we would need to set a realistic
community shared expectation regarding how much time is 
to be allowed for record updating, and the appropriate
intermediate steps along the path between "please come
in and update your records" and "we have reclaimed the
number resources that you thought were assigned to you"

By no means is this an encouragement for folks post-merger 
to skip updating their records at ARIN, but simply pointing 
out that we would need to have some compelling community 
guidance before changing the existing practices in this area.  
We are seeing more 8.2 updates as a result of folks realizing 
the importance of their number resources, and some as a result 
of interest in performing transfers, and this is definitely 
a step in the right direction for improving registry accuracy.
Creating a potential risk that ARIN would decide instead to
reclaim resources from part M&A activity would more likely
to inhibit rather than encourage updates.

FYI,
/John

John Curran
President and CEO
ARIN