Rocky,

Many such 8.2 transfers are efforts to get ARIN's records up to date regarding 
M&A transactions that happened years ago. It is not possible for a 
no-longer-existent entity to execute the 8.3 transfer, so it has to be 8.2 
transferred to the new entity first. 

Scott

> On Apr 3, 2014, at 6:02 PM, Rocky <[email protected]> wrote:
> 
> Hello there,
> 
> What you are planning to do  seems  like you try to disguise an 8.3 transfer 
> as an 8.2 transfer. 
> I do not think it is appropriate for  allowing an 8.2 transfer followed by an 
> 8.3/8.4 transfer. 
> 
> If the company does not need the IPv4 and the IPv4 are lack of utilisation,   
> why not ask this company to return the IPv4 for the benefit of the community?
> 
> If the company wants to sell the IPv4 after an 8.2 to buyers through an 
> 8.3/8.4,  why not the company directly transfer the IPv4 from its original 
> organisation instead of  doing  an 8.2 first then followed by an 8.3/8.4 
> transfer.   Are the seller  trying to hide something or as the seller is 
> afraid of doing something against the policy, so they try to make such an 
> arrangement?
> 
> There is a highly suspicious of “ IPv4 laundry” or “IPv4 speculation”  about 
> this company.     Maybe we need more transparency of the buy&sale of the IPv4 
> to make sure the behaviour of the seller is compatible with  policy. 
> 
> I suggest to resolve the language conflict between 8.2 transfer policy and 
> RSA and further to suggest to figure out some measures to stop the  
> speculation on IPv4  via an 8.2 then followed by an 8.3/8.4 transfer.      If 
> the company does not use the IPv4 after an 8.2 transfer, why not return them 
> to free pool for the benefit of the whole community?
> 
> Any ideas on this ?
> 
> 
>> On Friday, April 4, 2014 at 7:43 AM, [email protected] wrote:
>> 
>> Send ARIN-PPML mailing list submissions to
>> [email protected]
>> 
>> To subscribe or unsubscribe via the World Wide Web, visit
>> http://lists.arin.net/mailman/listinfo/arin-ppml
>> or, via email, send a message with subject or body 'help' to
>> [email protected]
>> 
>> You can reach the person managing the list at
>> [email protected]
>> 
>> When replying, please edit your Subject line so it is more specific
>> than "Re: Contents of ARIN-PPML digest..."
>> 
>> 
>> Today's Topics:
>> 
>> 1. Re: ARIN-PPML Digest, Vol 106, Issue 7 (Chris R. Squatritto)
>> 2. Re: Draft Policy ARIN-2014-9: Resolve Conflict Between RSA
>> and 8.2 Utilization Requirements (John Curran)
>> 3. Re: Draft Policy ARIN-2014-9: Resolve Conflict Between RSA
>> and 8.2 Utilization Requirements (Milton L Mueller)
>> 4. Re: Draft Policy ARIN-2014-9: Resolve Conflict Between RSA
>> and 8.2 Utilization Requirements (xiaofan yang)
>> 5. Re: Draft Policy ARIN-2014-9: Resolve Conflict Between RSA
>> and 8.2 Utilization Requirements (xiaofan yang)
>> 
>> 
>> ----------------------------------------------------------------------
>> 
>> Message: 1
>> Date: Wed, 02 Apr 2014 16:30:45 -0700
>> From: "Chris R. Squatritto" <[email protected]>
>> To: [email protected]
>> Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 106, Issue 7
>> Message-ID:
>> <[email protected]>
>> Content-Type: text/plain; charset="utf-8"
>> 
>> I am out of the office this week and will not be checking email. Please
>> contact Troy Miller for assistance..
>> 
>> Thank you for contacting me, and have a great day.
>> 
>> -------------- next part --------------
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>> 
>> ------------------------------
>> 
>> Message: 2
>> Date: Wed, 2 Apr 2014 23:59:20 +0000
>> From: John Curran <[email protected]>
>> To: xiaofan yang <[email protected]>
>> Cc: "[email protected]" <[email protected]>
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-9: Resolve Conflict
>> Between RSA and 8.2 Utilization Requirements
>> Message-ID: <[email protected]>
>> Content-Type: text/plain; charset="iso-8859-1"
>> 
>>> On Apr 2, 2014, at 4:27 PM, xiaofan yang <[email protected]> wrote:
>>> 
>>> Hi John,
>>> 
>>> I have further enquiry about ARIN 8.2 process.
>>> 
>>> Number one:I am also worried about the costs of doing a 8.2 transfer 
>>> followed by a 8.3 transfer. I wonder if I will have to involve the legal 
>>> help to deal with ARIN legal. In my case I bought a company that now is out 
>>> of business. How complicated does ARIN make this process? I want some 
>>> assurance that I will be treated equally to any other companies whether it 
>>> is a big company or a small company like us.
>> 
>> Niki -
>> 
>> You will be treated equally, but in truth I'm not certain that is actually 
>> what you want...
>> (for example, a process which seems routine for a large organization could 
>> still pose
>> a disproportionate burden to a smaller organization since organization size 
>> is not a
>> factor in the verification process.)
>> 
>> The first and foremost activity is to make sure that we have your 
>> organization registered
>> as the rightful address holder, and that will require an NRPM 8.2 transfer. 
>> It can actually
>> be relatively straightforward process, as long as you have clear 
>> documentation of the
>> purchase of the company. Review the instructions here for additional 
>> information about
>> what is accepted - 
>> <https://www.arin.net/resources/request/transfers_8_2.html>
>> 
>>> Number two: If we do a 8.2 transfer followed by a 8.3 transfer, will the 
>>> stated purpose for our number resources remains the same?? I am afraid of 
>>> that ARIN will not approve our transfer.
>> 
>> If you are the clear party with the rights after your purchase, ARIN will 
>> approve your
>> transfer. We may note that you have more addresses than you now need, and 
>> thus
>> we expect you to return or transfer the remainder (but that would seem to 
>> line up with
>> your intentions in any case.)
>> 
>> If you have purchased a company without adequate documentation, or if 
>> multiple
>> parties purchased multiple pieces of the company, or if there some question 
>> about
>> what was purchased based on the documentation, then it can be more 
>> challenging
>> to get the resources appropriately listed with you as the rightful holder. 
>> You will need
>> to apply for the transfer and work with the ARIN Hostmaster to determine if 
>> there is
>> any issue in your particular case.
>> 
>>> Number three: As we have bought the company, do we have the property right 
>>> on those IPs? in our past agreement and future agreement arranged for 8.3, 
>>> we would like to have some kinds of property right on those IPs, will that 
>>> conflict with ARIN policy?
>> 
>> Wonderful question - it is ARIN's position that you have a specific set of 
>> rights to the
>> address blocks in the registry (as defined by the registration services 
>> agreement that
>> you enter with ARIN), and these rights include:
>> 
>> (1) The exclusive right to be the registrant of the Included Number 
>> Resources within the ARIN database;
>> (2) The right to use the Included Number Resources within the ARIN database; 
>> and
>> (3) The right to transfer the registration of the Included Number Resources 
>> pursuant to the Policies.
>> 
>> ARIN registration services agreement includes a specific disclaimer of 
>> property rights
>> in the address blocks, as it is inconsistent with the ability to manage the 
>> address blocks
>> in accordance with community-developed policy in the region. If you have 
>> other beliefs
>> with respect to your rights, that would probably be an area for you to seek 
>> legal advice.
>> 
>> I hope this helps; please do not hesitate to ask if you have any additional 
>> questions.
>> 
>> Thanks!
>> /John
>> 
>> John Curran
>> President and CEO
>> ARIN
>> 
>> 
>> 
>> ------------------------------
>> 
>> Message: 3
>> Date: Thu, 3 Apr 2014 15:33:13 +0000
>> From: Milton L Mueller <[email protected]>
>> To: "'John Curran'" <[email protected]>, xiaofan yang
>> <[email protected]>
>> Cc: "[email protected]" <[email protected]>
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-9: Resolve Conflict
>> Between RSA and 8.2 Utilization Requirements
>> Message-ID: <[email protected]>
>> Content-Type: text/plain; charset="us-ascii"
>> 
>> Niki:
>> For most economists and lawyers, the definition of a "property right" 
>> involves the right to use, the right to exclude others from using, and the 
>> right to transfer. As John's message makes clear, all those rights are 
>> present in the number block lease you get from ARIN. So although the RSA 
>> makes you formally declaim a property right, what you are getting from the 
>> RSA is a bundle of rights that for all practical purposes has the same 
>> economic features as a property right.
>> 
>> -----Original Message-----
>> 
>> Wonderful question - it is ARIN's position that you have a specific set of 
>> rights to the address blocks in the registry (as defined by the registration 
>> services agreement that you enter with ARIN), and these rights include:
>> 
>> (1) The exclusive right to be the registrant of the Included Number 
>> Resources within the ARIN database;
>> (2) The right to use the Included Number Resources within the ARIN database; 
>> and
>> (3) The right to transfer the registration of the Included Number Resources 
>> pursuant to the Policies.
>> 
>> ARIN registration services agreement includes a specific disclaimer of 
>> property rights in the address blocks, as it is inconsistent with the 
>> ability to manage the address blocks in accordance with community-developed 
>> policy in the region. If you have other beliefs with respect to your rights, 
>> that would probably be an area for you to seek legal advice.
>> 
>> I hope this helps; please do not hesitate to ask if you have any additional 
>> questions.
>> 
>> Thanks!
>> /John
>> 
>> John Curran
>> President and CEO
>> ARIN
>> 
>> _______________________________________________
>> 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.
>> 
>> 
>> ------------------------------
>> 
>> Message: 4
>> Date: Fri, 4 Apr 2014 07:33:04 +0800
>> From: xiaofan yang <[email protected]>
>> To: John Curran <[email protected]>
>> Cc: "[email protected]" <[email protected]>
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-9: Resolve Conflict
>> Between RSA and 8.2 Utilization Requirements
>> Message-ID:
>> <caphl6mpzkw1q2cw9+sfz+hap6ecwns6jzdbep+xvk8df7vm...@mail.gmail.com>
>> Content-Type: text/plain; charset="iso-8859-1"
>> 
>> Hi John,
>> 
>> 
>> In basis of your reply, if the block is underutilised,ARIN will either ask
>> the company to return the IPs or transfer to other third party via 8.3
>> transfer after our 8.2 transfer.
>> 
>> 
>> Say we have two /16 after this 8.2 transfer, what if we only transfer one
>> /16 to the other third party via 8.3 transfer, meanwhile, we keep the
>> other /16 left unused after our 8.2 transfer for quiet a while. Will ARIN
>> ask us to return the remained /16 to the free pool? furthmore, how long
>> will ARIN allow us to keep the other /16 unused before we transfer it to
>> the third party via 8.3 transfer ?
>> 
>> 
>> 
>> Niki
>> 
>> 
>> 
>> 
>>> On Thu, Apr 3, 2014 at 7:59 AM, John Curran <[email protected]> wrote:
>>> 
>>>> On Apr 2, 2014, at 4:27 PM, xiaofan yang <[email protected]> wrote:
>>>> 
>>>> Hi John,
>>>> 
>>>> I have further enquiry about ARIN 8.2 process.
>>>> 
>>>> Number one:I am also worried about the costs of doing a 8.2 transfer
>>> followed by a 8.3 transfer. I wonder if I will have to involve the legal
>>> help to deal with ARIN legal. In my case I bought a company that now is
>>> out of business. How complicated does ARIN make this process? I want some
>>> assurance that I will be treated equally to any other companies whether it
>>> is a big company or a small company like us.
>>> 
>>> Niki -
>>> 
>>> You will be treated equally, but in truth I'm not certain that is actually
>>> what you want...
>>> (for example, a process which seems routine for a large organization could
>>> still pose
>>> a disproportionate burden to a smaller organization since organization
>>> size is not a
>>> factor in the verification process.)
>>> 
>>> The first and foremost activity is to make sure that we have your
>>> organization registered
>>> as the rightful address holder, and that will require an NRPM 8.2
>>> transfer. It can actually
>>> be relatively straightforward process, as long as you have clear
>>> documentation of the
>>> purchase of the company. Review the instructions here for additional
>>> information about
>>> what is accepted - <
>>> https://www.arin.net/resources/request/transfers_8_2.html>
>>> 
>>>> Number two: If we do a 8.2 transfer followed by a 8.3 transfer, will
>>> the stated purpose for our number resources remains the same?? I am afraid
>>> of that ARIN will not approve our transfer.
>>> 
>>> If you are the clear party with the rights after your purchase, ARIN will
>>> approve your
>>> transfer. We may note that you have more addresses than you now need, and
>>> thus
>>> we expect you to return or transfer the remainder (but that would seem to
>>> line up with
>>> your intentions in any case.)
>>> 
>>> If you have purchased a company without adequate documentation, or if
>>> multiple
>>> parties purchased multiple pieces of the company, or if there some
>>> question about
>>> what was purchased based on the documentation, then it can be more
>>> challenging
>>> to get the resources appropriately listed with you as the rightful holder.
>>> You will need
>>> to apply for the transfer and work with the ARIN Hostmaster to determine
>>> if there is
>>> any issue in your particular case.
>>> 
>>>> Number three: As we have bought the company, do we have the property
>>> right on those IPs? in our past agreement and future agreement arranged
>>> for 8.3, we would like to have some kinds of property right on those IPs,
>>> will that conflict with ARIN policy?
>>> 
>>> Wonderful question - it is ARIN's position that you have a specific set of
>>> rights to the
>>> address blocks in the registry (as defined by the registration services
>>> agreement that
>>> you enter with ARIN), and these rights include:
>>> 
>>> (1) The exclusive right to be the registrant of the Included Number
>>> Resources within the ARIN database;
>>> (2) The right to use the Included Number Resources within the ARIN
>>> database; and
>>> (3) The right to transfer the registration of the Included Number
>>> Resources pursuant to the Policies.
>>> 
>>> ARIN registration services agreement includes a specific disclaimer of
>>> property rights
>>> in the address blocks, as it is inconsistent with the ability to manage
>>> the address blocks
>>> in accordance with community-developed policy in the region. If you have
>>> other beliefs
>>> with respect to your rights, that would probably be an area for you to
>>> seek legal advice.
>>> 
>>> I hope this helps; please do not hesitate to ask if you have any
>>> additional questions.
>>> 
>>> Thanks!
>>> /John
>>> 
>>> John Curran
>>> President and CEO
>>> ARIN
>> -------------- next part --------------
>> An HTML attachment was scrubbed...
>> URL: 
>> <http://lists.arin.net/pipermail/arin-ppml/attachments/20140404/fd4aa749/attachment-0001.html>
>> 
>> ------------------------------
>> 
>> Message: 5
>> Date: Fri, 4 Apr 2014 07:43:43 +0800
>> From: xiaofan yang <[email protected]>
>> To: Milton L Mueller <[email protected]>
>> Cc: John Curran <[email protected]>, "[email protected]"
>> <[email protected]>
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-9: Resolve Conflict
>> Between RSA and 8.2 Utilization Requirements
>> Message-ID:
>> <CAPhL6MrQdn-=5g8zksntvpvca7prrwuwlxcaitrgv2d672w...@mail.gmail.com>
>> Content-Type: text/plain; charset="iso-8859-1"
>> 
>> Hi Milton,
>> 
>> thanks for your inspiring reply. Now i know that we have the "ownership"
>> of those IPs. as you are one of the AC, i take your reply seriously and
>> also this is good news for the community, especially for those legacy
>> holders, if the holder of ARIN non-legacy IPs can have the "ownership'
>> then the holder of legacy IPs definitely has the ownership on their IPs
>> no matter whether they sign the RSA , LRSA or not.
>> 
>> Hope ARIN will not impose unpredictable "restrictions" when legacy or
>> non-legacy holder begins its transfer request. Moreover, when ARIN reject
>> a transfer , hope ARIN will not use the "confidential terms" as an excuse
>> for not reply communities' questions in ppml. or ARIN will reply with
>> bunch of info mean nothing.
>> Niki
>> 
>> 
>>> On Thu, Apr 3, 2014 at 11:33 PM, Milton L Mueller <[email protected]> wrote:
>>> 
>>> Niki:
>>> For most economists and lawyers, the definition of a "property right"
>>> involves the right to use, the right to exclude others from using, and the
>>> right to transfer. As John's message makes clear, all those rights are
>>> present in the number block lease you get from ARIN. So although the RSA
>>> makes you formally declaim a property right, what you are getting from the
>>> RSA is a bundle of rights that for all practical purposes has the same
>>> economic features as a property right.
>>> 
>>> -----Original Message-----
>>> 
>>> Wonderful question - it is ARIN's position that you have a specific set of
>>> rights to the address blocks in the registry (as defined by the
>>> registration services agreement that you enter with ARIN), and these rights
>>> include:
>>> 
>>> (1) The exclusive right to be the registrant of the Included Number
>>> Resources within the ARIN database;
>>> (2) The right to use the Included Number Resources within the ARIN
>>> database; and
>>> (3) The right to transfer the registration of the Included Number
>>> Resources pursuant to the Policies.
>>> 
>>> ARIN registration services agreement includes a specific disclaimer of
>>> property rights in the address blocks, as it is inconsistent with the
>>> ability to manage the address blocks in accordance with community-developed
>>> policy in the region. If you have other beliefs with respect to your
>>> rights, that would probably be an area for you to seek legal advice.
>>> 
>>> I hope this helps; please do not hesitate to ask if you have any
>>> additional questions.
>>> 
>>> Thanks!
>>> /John
>>> 
>>> John Curran
>>> President and CEO
>>> ARIN
>>> 
>>> _______________________________________________
>>> 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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>> ------------------------------
>> 
>> _______________________________________________
>> ARIN-PPML mailing list
>> [email protected]
>> http://lists.arin.net/mailman/listinfo/arin-ppml
>> 
>> End of ARIN-PPML Digest, Vol 106, Issue 8
>> *****************************************
> 
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
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> Unsubscribe or manage your mailing list subscription at:
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