[arin-ppml] Draft Proposal for Needs-Free IPv4 Transfers
mike at nationwideinc.com
Tue May 10 18:40:02 EDT 2011
>> 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
>policies that were applicable the time of the merger. Prior to May
>means that an organization that acquires substantially all of the the
>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
>that hasn't been maintaining records comes to ARIN for the first time.
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
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.
But just to be clear, if a company came to ARIN today with evidence of
mergers and acquisitions which occurred prior to May, 2010, and that entity
currently had no use for the addresses, would ARIN aprove the prior 8.2
transfers and allow the holder to sell the addresses?
(Assuming there is evidence of transfer of network assets which used the
addresses when the mergers occurred.)
Would ARIN approve the prior 8.2 transfers and then do a resource review
under the RSA?
What if the addresses were legacy addresses, as they were in the MS/Nortel
These are the types of issues we will be facing and I thank you for the
excellent information you provide.
More information about the ARIN-PPML