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

Fri Feb 7 16:14:27 EST 2020

Thank you for the clarification Joe. I have no further discussion of this
draft at this time.
—
Brian Jones

On Fri, Feb 7, 2020 at 9:15 AM Joe Provo <ppml at rsuc.gweep.net> wrote:

>
> <AC hat>
>
> On Wed, Jan 29, 2020 at 01:43:25PM -0500, Brian Jones wrote:
> > On Wed, Jan 29, 2020 at 11:34 AM Andrew Dul <andrew.dul at quark.net>
> wrote:
> >
> > > I would say as a continuing ARIN member they are responsible for
> keeping
> > > up their POC and abuse records just like any other member.
> > >
> > > Andrew
> > >
> >
> > Point being, if those address blocks are ignored long enough, they could
> be
> > reclaimed eventually by ARIN for repurposing?
>
>
> Brian,
>
> Since none of the updates to language affected that, I'm
> with Andrew as the previous S&L would have specified. Once
> this language settles and we seek the next S&L we can call
> out the concern to be directly addressed so there's no
> ambiguity.
>
> To that end, it'd be great if we could get any additional
> feedback on the current language in the next week. I'd love
> to iron out any further changes so we can have concensus
> on the text by the next AC meeting
>
> </AC hat>
>
> Cheers!
>
> Joe
>
>
> > > On 1/28/2020 11:52 AM, Brian Jones wrote:
> > >
> > >
> > > Question: Does this mean that the entity responsible for the continued
> > > resource holdings is subject to keeping up the POC and abuse contact
> > > information for each of the locations or allocation blocks where it
> > > continues to use ARIN resources?
> > >
> > > ???
> > > Brian Jones
> > > NI&S Virginia Tech
> > > bjones at vt.edu
> > >
> > >
> > > On Tue, Jan 28, 2020 at 7:23 AM ARIN <info at arin.net> wrote:
> > >
> > >> The following has been revised:
> > >>
> > >> * Draft Policy ARIN-2019-12: M&A Legal Jurisdiction Exclusion
> > >>
> > >> Revised text is below and can be found at:
> > >>
> > >> https://www.arin.net/participate/policy/drafts/2019_12/
> > >>
> > >> You are encouraged to discuss all Draft Policies on PPML. The AC will
> > >> evaluate the discussion in order to assess the conformance of this
> Draft
> > >> Policy with ARIN's Principles of Internet number resource policy as
> > >> stated in the Policy Development Process (PDP). Specifically, these
> > >> principles are:
> > >>
> > >> * Enabling Fair and Impartial Number Resource Administration
> > >> * Technically Sound
> > >> * Supported by the Community
> > >>
> > >> The PDP can be found at:
> > >> https://www.arin.net/participate/policy/pdp/
> > >>
> > >> Draft Policies and Proposals under discussion can be found at:
> > >> https://www.arin.net/participate/policy/drafts/
> > >>
> > >> Regards,
> > >>
> > >> Sean Hopkins
> > >> Policy Analyst
> > >> American Registry for Internet Numbers (ARIN)
> > >>
> > >>
> > >>
> > >> Draft Policy ARIN-2019-12: M&A Legal Jurisdiction Exclusion
> > >>
> > >> Problem Statement:
> > >>
> > >> Merger and acquisition activity sometimes results in a surviving legal
> > >> entity that is not in ARIN service region, but may prefer to continue
> > >> the pre-existing relationship with ARIN.
> > >>
> > >> Example: Imagine a case where a global company has decided to
> > >> discontinue service in the ARIN service region (shuttering ARIN region
> > >> offices laying off ARIN region employees, and canceling ARIN region
> > >> customers) and repurpose the network resources and number resources in
> > >> the rest of its global footprint. During restructuring the company
> > >> concentrates its holdings in its European subsidiary, and then
> dissolved
> > >> its US legal entity.
> > >>
> > >> Imagine a case where a global company has decided to divest its
> service
> > >> in the ARIN region (selling all ARIN region offices, all ARIN region
> > >> network assets, all ARIN service region customers, all number
> resources
> > >> used in the ARIN (associated with previous noted sale of network and
> > >> customers), but retaining ARIN issued resources in use outside of the
> > >> ARIN service region. During restructuring the company concentrates its
> > >> holdings which are not in us in the ARIN service region in its
> European
> > >> subsidiary, and then sells off its US legal entity (including the
> > >> network, customers, addresses in use, etc) dissolved its US legal
> entity.
> > >>
> > >> Policy Statement:
> > >>
> > >> Add the following to section 8.2
> > >>
> > >> Mergers, acquisitions, and reorganization activity resulting in the
> > >> surviving entity ceasing to have a real and substantial connection
> with
> > >> the ARIN region shall be permitted to continue holding any numbering
> > >> resources issued (directly or indirectly) by ARIN prior to the merger,
> > >> acquisition or reorganization activity, but shall not qualify for any
> > >> additional numbering resources (directly or indirectly) from ARIN,
> > >> unless and until it once again has a real and substantial connection
> > >> with the ARIN region as required by the Numbering Resource Policy
> Manual.
> > >>
> > >> Timetable for Implementation: Immediate
> > >>
> > >> Anything Else:
> > >>
> > >> This proposal may be overtaken by a more general approach to ARIN
> > >> membership legal jurisdiction exclusion
> > >>
> > >> To clarify scope, a legal entity present within the ARIN service
> region,
> > >> and 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.
> > >>
> > >>
> > >> _______________________________________________
> > >> ARIN-PPML
> > >> You are receiving this message because you are subscribed to
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> > >> Unsubscribe or manage your mailing list subscription at:
> > >> https://lists.arin.net/mailman/listinfo/arin-ppml
> > >> Please contact info at arin.net if you experience any issues.
> > >>
> > >
> > > _______________________________________________
> > > ARIN-PPML
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> > >
> > >
> > > _______________________________________________
> > > ARIN-PPML
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> > >
>
> > _______________________________________________
> > ARIN-PPML
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>
> --
> Posted from my personal account - see X-Disclaimer header.
> Joe Provo / Gweep / Earthling
>
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