<html><head></head><body style="word-wrap: break-word; -webkit-nbsp-mode: space; -webkit-line-break: after-white-space; "><div><blockquote type="cite"><div><font class="Apple-style-span" color="#000000"><br></font>8.2. Mergers and Acquisitions<br><br>ARIN will consider requests for the transfer of number resources in the<br>case of properly documented mergers and acquisitions. ARIN will<br>maintain an up-to-date list of acceptable types of documentation.<br><br></div></blockquote>Perhaps ...ARIN staff will...</div><div><br><blockquote type="cite"><div>In the event that number resources of the acquired/merged<br>organization(s) are no longer efficiently utilized at the time ARIN<br>becomes aware of the transaction, through a transfer request or<br>otherwise, ARIN will work with the resource holder(s) to return or<br>aggregate resources as appropriate via the processes outlined in<br>sections 4.6, 4.7, or 12 of the NRPM.<br><br></div></blockquote>I think that there's an issue here. I think that we need to talk about</div><div>the number resources of the resultant combined organization rather</div><div>than of the acquired/merged organization... Here's why...</div><div><br></div><div>The term acquired/merged could be construed to refer only to the</div><div>resources that were acquired without regard for the resources already</div><div>held by the acquiring organization. Let's say that two organizations</div><div>A and B merge. Prior to merger, A efficiently used 17 /24s and held</div><div>a /19, while B efficiently used a /23 and held a /22. The combined</div><div>usage is 19 /24s which would justify a /19, but, would not justify the</div><div>/22 of additional space. The /22 should be returned in this case and</div><div>be renumbered into the /19.</div><div><br></div><div><blockquote type="cite"><div>Add "In addition to transfers under section 8.2, " at the beginning of<br>section 8.3. Transfers to Specified Recipients.<br><br></div></blockquote>Otherwise, looks good to me.</div><div><br></div><div>Owen</div><div><br></div><div><br><blockquote type="cite"><div>Rationale:<br><br>This policy proposal: attempts to simplify the M&A transfer section of<br>the NRPM; eliminates the ambiguity discussed at the ARIN Public Policy<br>Meeting (PPM) in Dearborn by clarifying that transfers can occur under<br>either 8.2 or 8.3 independently; and attempts to address the concerns<br>raised in the staff policy implementation report at the Dearborn PPM.<br><br>The idea here is to simply say that ARIN will allow M&A transfers, and<br>to require the return of any address space that is not efficiently<br>utilized after the acquisition. Preferably that would happen<br>voluntarily under the policies of NRPM 4.6 (Amnesty), but it also leaves<br>the door open for ARIN to revoke space under NRPM 12 (Resource Review)<br>if necessary. This also should dramatically increase the completion<br>rate for transfer requests, as the evaluation of whether space is<br>efficiently utilized after the transfer can occur in parallel,<br>completely independently of the transfer request, and can continue even<br>if the transfer request is abandoned.<br><br>The bulleted lists of acceptable documentation removed from the NRPM<br>should be maintained by ARIN elsewhere on the website, such as at<br><a href="https://www.arin.net/resources/request/transfers.html">https://www.arin.net/resources/request/transfers.html</a><br><br>Timetable for implementation: Immediate<br><br><br>_______________________________________________<br>PPML<br>You are receiving this message because you are subscribed to<br>the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).<br>Unsubscribe or manage your mailing list subscription at:<br>http://lists.arin.net/mailman/listinfo/arin-ppml<br>Please contact info@arin.net if you experience any issues.<br></div></blockquote></div><br></body></html>