[arin-ppml] Draft Policy ARIN-2019-12: M&A Legal Jurisdiction Exclusion

David Farmer farmer at umn.edu
Wed Oct 23 15:15:40 EDT 2019


I also like this language for the policy text and inclusion in section 8.2
of the NRPM.

However, I still like the idea of adding to the other comments section of
this Draft Policy, something like the following;

To clarify more broadly, a legal entity present within the ARIN service
region, with a current ARIN RSA executed with that entity, is necessary to
receive allocations or assignments from ARIN. Therefore, in the scenario
postulated in the problem statement, the organization would have to
re-establish itself within the ARIN service region to receive additional
resources from ARIN, while it can continue to hold the allocations or
assignments made prior to any merger, acquisition, or reorganization
activity.

Thanks

On Wed, Oct 23, 2019 at 1:31 PM John Santos <john at egh.com> wrote:

> I prefer this wording to any of the previous proposals.  I believe it
> satisfies the intent of all the previous proposals and I don't have any
> specific problems with it. I think it covers all the issues and edge cases.
>
> On 10/23/2019 01:38 PM, Owen DeLong wrote:
> > Joe,
> >
> > On M&A, I agree it’s a corner case, but there is the possibility of a
> > scenario
> > involving marriage, divorce, adoption, etc. to fall within section 8.2.
> > Not sure it’s a sufficient case to bother addressing.
> >
> > I do like the additional clarity, but agree that we should avoid
> > language that
> > is specific to corporations.
> >
> > Suggest:
> >
> > “M&A activity resulting in the surviving legal entity having no presence
> > in the
> > ARIN service region will be permitted and such entity may retain any
> > existing
> > number resource holdings under their existing ARIN RSA.”
> >
> > I believe this addresses all natural and artificial legal entities in
> > virtually all
> > cases mentioned to date while preserving the core intent of the original
> > proposal.
> >
> > Owen
> >
>
> --
> John Santos
> Evans Griffiths & Hart, Inc.
> 781-861-0670 ext 539
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