[arin-ppml] ARIN-prop-173 Revisions to M&A TransferRequirements(Updated Version)

[sandrabrown at ipv4marketgroup.com]

<SNIP>
from the proposal:
>>>>>>>>>>>>>>>>
Transfers under 
this Section 8.2 shall not be contingent upon the new entity's 
justification of need for the transferred numbers.

<<<<<<<<<<<<<<<<<<<<<<<

 
I support Marc Lindsay's proposal.  It woud be a significant improvement
over the current 8.2.  While I was with Nortel, we avoided transferring
any legacy blocks that were in the names of Bay Networks, Xylogics,
Synoptics, and other past acquisitions, as it made no sense to go
through needs assessment as part of that process.  
 
Also, as I have posted in the past, I believe the accuracy of the
registration database is the most important duty of the ARIN Advisory
Council, and this will help the AC to fulfill that duty.  
 
Think of the numerous companies that are partially using their blocks,
have no intention of monetizing those blocks, and they, under the
current 8.2 policy, would have to prove their needs assessment to
justify keeping addresses in order to update their registration.  
 
At present, I don't think they will come forward, and risk being told to
aggregate internally generating tons of engineering and operational
work, and thus, the ARIN database would remain out of date.  While ARIN
often promises to behave reasonably, and has historically tried to make
its own rules work, this case would require something secret like a
fictitious needs assessment, and I have only heard that to be in
Microsoft and Cerner's copies of the ARIN Manual.  
 
Mr. Lindsay's proposal will help to overcome this problem.  
 
<SNIP>
from the proposal:
>>>>>>>>>>>>>>>>
8.2.1 If the transfer request pertains to non-legacy numbers or legacy 
numbers governed by an LRSA or RSA at the time such transfer request is 
first submitted to ARIN, the new entity shall be required to execute, in

its own name, an RSA covering the transferred numbers, and pay the 
applicable registration fees.
<<<<<<<<<<<<<<<<<<<<<<<
 
This new proposal will not totally overcome the problem for those under
LRSA.  It continues to punish those who have consumed the ARIN koolaid
and have mistakenly signed an LRSA.  If their ARIN records are
incorrect, and they update the transfer information, it will further
punish them by converting their LRSA to an RSA.  Perhaps that aspect can
be fixed in the proposal.
 
As a sidenote, this is a good problem for ARIN to address.  We at IPv4
Market Group have many times been asked by companies contemplating sales
of IPv4 assets if they should first do an 8.2 transfer and we have to
tell them no, due to the punitive wording of 8.2.  They are much better
off to leave their registrations incorrect until they can arrange a
sale, and this is not in the best interest of an accurate Internet.
 
Sandra Brown, speaking both as myself, and on behalf of IPv4 Market
Group