William,

Thanks for your thoughts.

I proposed the policy for two reasons:

1) There are unanticipated consequences of the anti-flip language that make it 
impossible for companies to both be truthful with ARIN and to move blocks where 
they need to be.  Think of a large international network which sources 
addresses from ARIN for its backbone.  When it needs to move a block to 
APNIC-region registries due to both technical and geo-location reasons, it is 
unable to do so if it received space from ARIN within the last 12 months.  The 
"subsidiaries" part is due to legal realities:  the holding company in APNIC 
region is legally distinct from the HQ organization.  Again, the policy 
motivates lying to ARIN to get things done, and that's a lose-lose.

2) Anti-flipping language is obsolete with ARIN exhausted of large blocks, so 
when thinking about the policy, I originally wanted to just remove it.  But the 
PPML reality is I didn't think people would go for it, so to concentrate on the 
actual problem I wanted solved, I proposed an intermediate step.

I hope you will support the revised language, as it is intended to allow 
network operators to properly and honestly manage their registrations.

/david

David R Huberman
Microsoft Corporation
Senior IT/OPS Program Manager (GFS)

-----Original Message-----
From: [email protected] [mailto:[email protected]] On Behalf 
Of William Herrin
Sent: Thursday, January 30, 2014 8:44 AM
To: Bill Darte
Cc: [email protected]
Subject: Re: [arin-ppml] Draft Policy ARIN-2014-2: Improving 8.4 Anti-Flip 
Language

On Thu, Jan 30, 2014 at 7:11 AM, Bill Darte <[email protected]> wrote:
> What if an organization
> wishes to transfer to an 'existing' subsidiary....is that the same 
> organization?

Howdy,

For consistency's sake with the rest of the NRPM, it is not the same 
organization.


> ...and, is this issue 'really' of concern given the late date relative 
> to ARIN free-pool run out?

I'd find that a reasonable argument for eliminating the anti-flipping 
provisions entirely. As an argument for creating unfairness in the 
anti-flipping provisions, and worse: unfairness biased against the domestic 
folks it is ARIN's core mission to serve, I find that argument unpersuasive.

Regards,
Bill Herrin




--
William D. Herrin ................ [email protected]  [email protected]
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/> Falls 
Church, VA 22042-3004 _______________________________________________
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