Thanks to Owen and Scott for beginning a conversation about this Draft. Scott....given the other restriction that you reference, do you prefer one alternative over another....does the addition of an operational time frame associated with option #2 improve its ability to accomplish the problem statement.....
"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." This accidentally 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 block being used in Asia over to APNIC. The block was legacy. But because we had gotten a new block in 2013, we were prevented from moving the old block to a different RIR." bd On Sat, Feb 22, 2014 at 5:28 PM, Scott Leibrand <[email protected]>wrote: > There is another restriction already in 8.3, which reads "The source > entity will be ineligible to receive any further IPv4 address allocations > or assignments from ARIN for a period of 12 months after a transfer > approval, or until the exhaustion of ARIN's IPv4 space, whichever occurs > first." In light of that, do you still see a problem with #3? > > -Scott > > > On Sat, Feb 22, 2014 at 3:06 PM, Owen DeLong <[email protected]> wrote: > >> Several options are being discussed regarding this proposal: >> >>> >> 1. Use the existing last sentence as is and ask ARIN staff to be >> particularly watchful for seeming abuse and to bring such back to the >> community through regular Policy Experience Reports. There was discussion >> about this option suggesting that by the time abuse was recognized and >> reported, and given limited existing free pool stocks and the extended >> policy development cycle....this option is mute. >> >> 2. Remove the clause 'and its subsidiaries' and or modify it in such a >> way as to mitigate the risk of a laundering of addresses through fraudulent >> transfers, but potentially limit the utility of organizations who may have >> complex organizations structures in use internationally. >> >> 3. Take an alternative tack and simply restrict the Inter-RIR re-org >> transfer of the 'recently issued block' only, allowing other existing >> blocks to be transferred without restriction by recent block acquisition. >> This alternative seems to have been expressed and supported in the recent >> Atlanta Public Policy Consultation. >> >> >> It is my opinion that option 3 is perilous in that it allows a large >> resource holder to sell off their address space out of region while >> backfilling from the ARIN free pool. >> >> As such, I am much more comfortable with option 2. One set of language >> that was suggested which I like is: >> >> "...subsidiaries having been operational for a minimum of 18 months." >> >> While this might not prevent all possible subsidiary-based rinse-repeat >> abuse scenarios, it would at least prevent the obvious subsidiary created >> for this purpose scenario and certainly provides better protections than >> proposal number 3. >> >> I think option 1 is probably an unfair burden for the ARIN staff and >> makes policy vague in a way that would be difficult, if not impossible, to >> reliably enforce and may be even harder to defend in the event of >> litigation. This is strictly my own opinion as a member of the community >> and I have not discussed the matter with legal council or even the other >> members of the AC. >> >> Owen >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. >
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