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

Owen DeLong owen at delong.com
Thu Jul 5 19:23:02 EDT 2012

> OK,
> I agree that it shouldn't matter how big you are If you need to aggregate or renumber you need to do it.  However, big or small, legacy or not, why should you have to aggregate and return addresses because you change the name of the organization? Why should that event trigger that?

8.2 covers a lot more than just an organizational name change.

If you have a company that was holding a /16 and had usage which just barely justified that /16 and they merge with a company holding a /9 which has more than a /14 of free space (which is still 80% utilization), then there is no reason that the /16 should not be renumbered into the /9 and reclaimed. I support giving an extended period to accomplish the renumbering, but I do not support removing needs basis.

> If a mom and pop organization changes its name they should be able to update the records with the new name without having to rejustify their use, its not about size.  If they we justified under the old name why shouldn't they be justified under the new name?  The use didn't change by changing the name.

You are assuming that 8.2 only covers name changes. It does not. In fact, as I understand it, a name change does not require an 8.2 or 8.3 transfer if you can show that the new name and the old name are the same entity and not an ownership change.

> If you are changing the use by transferring the number resource independently then yes you need to rejustify the use, that is what 8.3 is about.  But, why for a name change, that seems like a high bar for something that trivial.

There are other ways to change use or change the dynamics of the use which often occur around mergers and acquisitions.

> I don't agree with most of the rest what she said, but on this issue I agree It creates a disincentive for updating the registry.

It creates some disincentive to update the registry, but, there are many areas where having inconvenient policy creates a disincentive to conform to policy. I do not buy that as a reason to eliminate the policy in and of itself.


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