<div dir="ltr">Hello,<div><br></div><div>As policy shepherd for DP-2014-2, I am interested in comments about the problem statement, need and efficacy of language drafted. I have included current information below. A statement of support or opposition and brief reasoning would be most helpful, but also suggestions on improvement are also welcomed if you feel this draft moves our region in a positive direction, but currently misses the mark. Thanks!</div>
<div><br></div><div><b>Problem Statement:</b></div><div><div><u>Current NRPM Language</u>: “Source entities within the ARIN region must not have received a transfer, allocation, or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. This restriction does not include M&A transfers.”</div>
<div><br></div><div>This prevents anyone who receives BLOCK A in 2014 from transferring to another RIR a different block, BLOCK B, which was issued 5, 10, 15, 20 years ago. In my company, we needed to move a legacy block being used in Asia over to APNIC. But because we had gotten a new block in 2013, we were prevented from moving the old block to a different RIR.</div>
</div><div><br></div><div><b><u>Proposed Language Modification: (Draft Policy statement) Change undelined</u></b></div><div>Source entities within the ARIN region must not have received a transfer, allocation, or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. This restriction does not include M&A transfers. <u>Restrictions related to recent receipt of blocks shall not apply to inter-RIR transfers within the same organization and its subsidiaries.</u><br>
</div><div><u><br></u></div><div>One comment has suggested that the clause '<b>and its subsidiaries</b>' opens opportunity for abuse.......another comment attempting to mitigate this possibility suggested the clause be modified as....'<span style="font-family:arial,sans-serif;font-size:13px">and its subsidiaries</span><span style="font-family:arial,sans-serif;font-size:13px"> <b>providing network services</b>'</span></div>
<div><span style="font-family:arial,sans-serif;font-size:13px"><br></span></div><div><span style="font-family:arial,sans-serif;font-size:13px">Thank you for sharing your insights and for being part of the ARIN open, bottom up, policy development process.</span></div>
<div><span style="font-family:arial,sans-serif;font-size:13px"><br></span></div><div><span style="font-family:arial,sans-serif;font-size:13px">Bill Darte</span></div><div><span style="font-family:arial,sans-serif;font-size:13px">ARIN Advisory Council</span></div>
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