[arin-ppml] ARIN-prop-173 Revisions to M&A TransferRequirements(Updated Version)
dogwallah at gmail.com
Thu Jul 5 17:25:05 EDT 2012
On Thu, Jul 5, 2012 at 4:31 PM, <sandrabrown at ipv4marketgroup.com> wrote:
> 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.
Responsibilities of the AC are listed here:
I'm not sure I would put accuracy of WHOIS data on their plate as
well, the list is long enough I would think.
> 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.
this seems to be a trivial requirement to me...YMMV.
> At present, I don't think they will come forward, and risk being told to
> aggregate internally generating tons of engineering and operational
Do RIRs tell folk how to number their network? I think this is a red-herring.
and thus, the ARIN database would remain out of date.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.
What case are you referring to above?
> Mr. Lindsay's proposal will help to overcome this problem.
> 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.
So now we see the heart of the matter. Your concern over the accuracy of
WHOIS data takes a back seat to profit via the sale of v4 resources
(and your commission presumably).
8.1 and 8.2 are, at the moment clauses I can grok at first reading.
I can't say the same for this proposal.
"A name indicates what we seek. An address indicates where it is. A
route indicates how we get there." Jon Postel
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