On Jan 29, 2014, at 7:06 PM, William Herrin <[email protected]> wrote:

> "and its subsidiaries" defeats the anti-flipping provision. Creating
> and then selling a "subsidiary" has a trivial cost.

Bill - 
 
  That concern could be addressed by using the phrase "and its subsidiaries
  providing network services"; such language would be safely understood to 
  encompass operating subsidiaries and their networking needs, and I will 
  note that deal with similar situations today under some NRPM 8.2 transfers 
  due to reorganizations.

  I am not advocating for or against the draft policy, but providing this 
  information solely to assist in clarity of discussion by the community.

Thanks!
/John

John Curran
President and CEO
ARIN

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