"Niki",


I'm confused by the questions, because the answers seem obvious, don't they?



Did you buy a company that has two /16s?  Just keep company X operating as 
company X! Find a buyer for one /16, and have the company you bought - company 
X - do an 8.3 transfer to the buyer.  It's not relevant to the process that 
your main company bought company X - it just adds unnecessary complexity to the 
ARIN process.  Then find a second buyer for a second /16 and repeat.



I guess it's possible it's too late - that company X is already closed and all 
of its assets are legally owned by your main company.  If that happened to me, 
then I would just find a buyer who wants the first /16. Then I'd submit an 8.3 
transfer to sell it to them.  During the 8.3 transfer, ARIN will ask you for 
documentation that shows you own the company X that has the Whois registrations 
today.  You show them the legal documentation, then you move on to the 8.3 part 
of the transfer.  I'm not sure why you're worried about ARIN taking back the 
second /16 which isn't sold yet. RSA paragraph 6 says they can't do that.



N.B. I am not your lawyer, and I am not providing you with legal advice. I am 
not providing you advice on behalf of my employer, and I do not speak for my 
employer.



/david









________________________________

From: [email protected] <[email protected]> on behalf of 
xiaofan yang <[email protected]>
Sent: Friday, April 4, 2014 7:19 PM
To: [email protected]
Cc: [email protected]
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 106, Issue 8

Hi Kevin,

I am quite confused by John's explanation too.
It seems ARIN always provides plenty of information meaning nothing.
Same happens to ask HM, HM will always  reply neutrally and I still cannot know 
it is yes or no!

However, in basis of john's reply i will rephrase his explanation as the 
following meaning:

I will try my best to transfer the two /16 to third party via 8.3/8.4 transfer 
immediately after a 8.2 transfer instead of reserving one /16 for another 
future sale in case of the other /16 to return to ARIN free pool or  rejecting 
for our second /16 transfer in future.

Niki



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.

Correct.

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 -

ARIN will continue to work with you as needed, so long as you are still working
in good faith towards compliance with policy. For more information on your
particular circumstances, please contact 
<[email protected]<mailto:[email protected]><mailto:[email protected]>>.

Thanks!
/John

John Curran
President and CEO
ARIN

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