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

[Brian Jones]

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


> 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.
>>
>>
>> _______________________________________________
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>>
>
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