<div><br></div>In my buy-merger-sell experience, <span></span>most companies don't complete transfers post M&A because they dont want to deal with ARIN. It's not worth the difficulty. Accuracy of the registry suffers again. <div>
<br></div><div>Best, </div><div><br></div><div>Martin <br><br>On Thursday, March 20, 2014, Sweeting, John <<a href="mailto:john.sweeting@twcable.com">john.sweeting@twcable.com</a>> wrote:<br><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">
Hi David<br>
<br>
I usually do not weigh in on active policy proposals but I did want to point out that a lot companies do not complete transfers during M&A activities simply because they do not have the resources to do so. The one (or half) person they have dealing with IP resources usually cannot even keep up with normal workload, let alone the additional workload associated with M&A activity. At least that has been my experience over many years and more than a few M&A events.<br>
<br>
Sent from my iPhone<br>
<br>
> On Mar 20, 2014, at 4:51 PM, "David Huberman" <<a>David.Huberman@microsoft.com</a>> wrote:<br>
><br>
> In contrast to my friend Owen, not only do I believe there is a very serious issue, but I believe this<br>
> proposal is necessary for ARIN to have any hope of being relevant in the years to come. I don't<br>
> mean to use that kind of hyperbole, but the issue is very real from my viewpoint. Allow me to<br>
> explain.<br>
><br>
> There are two different problems which this policy proposal solves.<br>
><br>
> 1. Whois accuracy<br>
> =============<br>
><br>
> As an ARIN Hostmaster for 10 years, I saw a very high rate of legitimate transfers which were<br>
> abandoned by the requestor. In turn, Whois did not get updated, and in most cases, remains<br>
> out of date today.<br>
><br>
> Think about that for a moment please: legitimate M&A activity occurred, but Whois never<br>
> got updated. That's a failure of the system. Why does it fail?<br>
><br>
> The common scenario is straight forward:<br>
><br>
> 1. Company A buys company B.<br>
> 2. Company A submits a transfer request to ARIN to have the IP address and AS number<br>
> registrations reflect that Company A is now the registrant.<br>
> 3. ARIN starts asking questions about the utilization of the number resources.<br>
> 4. Company A walks away from the transfer and never returns.<br>
><br>
> Step 3 is the consistent problem. In many cases, Company A never even submits the transfer<br>
> request because they are scared off by step 3. In some cases, it's because they don't KNOW<br>
> how the IP addresses are being used. In some cases, some IP addresses are used, and others<br>
> are not, and they think that if ARIN finds that out, they are going to take the addresses away.<br>
> In some cases, none of the addresses are used. But Company A is expanding their network<br>
> (or plans to) and wants to use the IP addresses of Company B which they now own.<br>
><br>
> Current policy does not work for these common scenarios. I conclude that having seen<br>
> thousands of transfers cross through the ARIN ticket system and talked to these requestors<br>
> over the phone for 10 years.<br>
><br>
> The takeaway from the above is that Whois is not accurate, in part because ARIN policy<br>
> demands justification for addresses which, regardless of whether Whois is updated or not,<br>
> Company A is going to use.<br>
><br>
> In December, the PPML list requested metrics from ARIN staff to show the extent of abandoned<br>
> transfers. The metrics provided were as follows:<br>
><br>
> === 8.2 Transfer Request Stats<br>
><br>
> 2011:<br>
><br>
> 422 8.2 transfers requested<br>
> 226 8.2 transfers approved (54%)<br>
> 209 8.2 transfers completed (50%)<br>
><br>
> 2012:<br>
><br>
> 451 8.2 transfers requested<br>
> 264 8.2 transfers approved (59%)<br>
> 241 8.2 transfers completed (53%)<br>
><br>
> 2013 YTD:<br>
><br>
> 445 8.2 transfers requested<br>
> 280 8.2 transfers approved (63%)<br>
> 269 8.2 transfers completed (60%)<br>
><br>
> If you review the thread in December, these stats generated a lot of discussion. I am among<br>
> the many who believe that a 40% abandonment rate FOR LEGITIMATE M&A ACTIVITY belies<br>
> a shortcoming in ARIN policy. There's a barrier that must be removed, and my experience<br>
> teaches me that it is the utilization requirements of NRPM 8.2.<br>
><br>
> Now to the second problem.<br>
><br>
><br>
> 2. Conflict with the RSA:<br>
> ==================<br>
><br>
> John Curran can give a more accurate and nuanced history, but as best I can recall, ARIN<br>
> tried to bring more legacy registration holders into the registry system by offering a<br>
> Legacy Registration Services Agreement. One of the takeaways from that initial effort<br>
> was that legacy registration holders were unwilling to sign any agreement which technically<br>
> allowed ARIN to de-register address space that they had without their consent.<br>
><br>
> One of the concessions made over time was language in the RSA documents which<br>
> removed that concern; it prohibits ARIN from forcibly taking away space when the<br>
> signer is in compliance with the other terms and conditions of the contract.<br>
><br>
> This new language, however, directly conflicts with the plain language of the NRPM 8.2<br>
> paragraph that this policy proposal seeks to remove.<This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this E-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this E-mail is strictly prohibited and may be unlawful. If you have received this E-mail in error, please notify the sender immediately and permanently delete the original and any copy of this E-mail and any printout.<br>
_______________________________________________<br>
PPML<br>
You are receiving this message because you are subscribed to<br>
the ARIN Public Policy Mailing List (<a href="javascript:;" onclick="_e(event, 'cvml', 'ARIN-PPML@arin.net')">ARIN-PPML@arin.net</a>).<br>
Unsubscribe or manage your mailing list subscription at:<br>
<a href="http://lists.arin.net/mailman/listinfo/arin-ppml" target="_blank">http://lists.arin.net/mailman/listinfo/arin-ppml</a><br>
Please contact <a href="javascript:;" onclick="_e(event, 'cvml', 'info@arin.net')">info@arin.net</a> if you experience any issues.<br>
</blockquote></div>