khatfield at socllc.net khatfield at socllc.net
Fri Jun 27 00:35:03 EDT 2014

I am in complete agreement with Owen. Additionally, I disagree on a change based on a business sale. The policies enforced for M&A have worked thus far.

No one should be able to sell addresses as part of a business sale. There should be  enough cooperation as part of the sale to allow a request and validation through ARIN after/during the a business transfer. This ensures the purchasing company isn't hoarding.

Despite Jeffrey Lyon's previous request asking the community to not assume he has an "ulterior motive", I can respectfully ensure everyone that he does. 

Since Jeff has brought this up. I would also like to state that upon sale of some of my companies specific business assets, IP's not included. A sale with loan, which The IRC Company/Black Lotus chose to default on, with confirmation by the circuit court of Delaware. We have since been unable to get our previous host - Black Lotus to stop announcing our owned subnets and AS.

Despite requests to their upstream providers we continue to be unable to use IP's we currently pay for. We additionally continue to receive spam notices, notices of racist (white power websites) being hosted on our IP's (by Black Lotus) as well as pretty much anything else they wouldn't normally host on their own IP's. Thereby, leaving my company with the legal implications of their continued abuse. Since Jeff was unable to default on us and take the IP's - you can see where this request is coming from.

Therefore, I wish to ask the community to watch carefully for his "ulterior motives".

Kevin Hatfield
Carrier Communications, Inc.

> On Jun 26, 2014, at 6:24 PM, "Owen DeLong" <owen at delong.com> wrote:
>> On Jun 26, 2014, at 11:52 , Andrew Dul <andrew.dul at quark.net> wrote:
>>> On 6/2/2014 10:34 AM, Heather Schiller wrote:
>>> At the PPM in April, there was support for leaving this paragraph in
>>> the NRPM, but removing the words 'aggregate' and 'return', resulting
>>> in the text below.   The AC encourages feedback on this proposed change.
>>> Thanks,
>>> --Heather
>>> Draft Policy ARIN-2014-9
>>> Resolve Conflict Between RSA and 8.2 Utilization Requirements
>>> Remove the words "aggregate" and "reclaim" from 8.2, so it reads:
>>> "In the event that number resources of the combined organizations are
>>> no longer justified under ARIN policy at the time ARIN becomes aware
>>> of the transaction, through a transfer request or otherwise, ARIN will
>>> work with the resource holder(s) to return or transfer resources as
>>> needed to restore compliance via the processes outlined in current
>>> ARIN policy."
>> This new text removes the threat of reclamation from the policy manual
>> as the current RSA (section 6) prohibits ARIN from reclaiming addresses
>> for lack of use, but this rewrite does not make it clear that an
>> organization can retain their addresses for future use.  This change
>> makes it clear that resources or parts of resources will not become
>> orphaned blocks due to a merger or acquisition.  I believe this change
>> would promote registry accuracy as it should allow organizations to
>> update all their records to show the new holder and user of the
>> resources regardless of utilization. 
>> May I suggest the following rewrite to clarify that an organization can
>> retain their addresses through a transfer.
>> ...ARIN will notify the resource holder(s) that they may return or
>> transfer resources as needed to restore compliance via the processes
>> outlined in current ARIN policy or retain their resources for future use
>> or later transfer/return.
> I would not support this change. It is not the intent of the policy to facilitate
> hoarding addresses for future use which is what this would enable.
> While ARIN is prohibited by (errors in) the RSA from reclaiming resources
> under this circumstance, I believe it is still appropriate for policy to require
> holders to take action to restore their networks to compliance with the intent
> of policy.
> Owen
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