You are free to call it misguided as much as you wish.

However, I believe that the notion that turning the RIR system into a 
collection of auction houses just because the free pool ended is even more 
misguided, so I guess we should simply agree to disagree about that.

Owen

> On May 31, 2015, at 11:31 AM, Matthew Kaufman <[email protected]> wrote:
> 
> Anti-flip shouldn't matter the moment there's no free pool left to allocate 
> from.
> 
> Unless you have some misguided notion that policy hacks are really going to 
> meaningfully impact the full-fledged transfer-only market for v4 space. 
> There's so many ways to structure transactions that policy attempts will be 
> futile.
> 
> Matthew Kaufman
> 
> (Sent from my iPhone)
> 
> On May 31, 2015, at 11:10 AM, Owen DeLong <[email protected] 
> <mailto:[email protected]>> wrote:
> 
>> I don’t think anyone has said any such thing, Milton.
>> 
>> What we have said is that it seems impossible to allow relaxed inter-RIR 
>> transfers within an organization in a way that preserves the anti-flip 
>> provisions the community has deemed necessary without having globally 
>> coordinated policy for the anti-flip provisions.
>> 
>> Whether you support having such a thing or not, that much seems to be simply 
>> the facts of the situation.
>> 
>> The policy in China is unrelated except to the extent that it was used as an 
>> example of a reason that relaxed transfer policy is needed.
>> 
>> Owen
>> 
>>> On May 31, 2015, at 7:49 AM, Milton L Mueller <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>> 
>>> It’s very naïve for people to suggest that national policy in China is 
>>> going to be affected by a global policy of RIRs.
>>> --MM
>>>   <>
>>> From: [email protected] <mailto:[email protected]> 
>>> [mailto:[email protected] <mailto:[email protected]>] On 
>>> Behalf Of Rudolph Daniel
>>> Sent: Saturday, May 30, 2015 5:49 PM
>>> To: [email protected] <mailto:[email protected]>
>>> Subject: Re: [arin-ppml] ARIN-PPML 2015-2
>>>  
>>> >>>That?s why I didn?t propose language? I don?t think the issue in 
>>> >>>question can be unilaterally addressed, so I think we should accept that 
>>> >>>and those that are interested can begin work on a globally coordinated 
>>> >>>policy if they desire to do so.<<<
>>> 
>>> Tend to agree ...It may be better addressed at global policy level if at 
>>> all.
>>> RD
>>> 
>>> On May 30, 2015 12:00 PM, <[email protected] 
>>> <mailto:[email protected]>> wrote:
>>> Send ARIN-PPML mailing list submissions to
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>>> 
>>> Today's Topics:
>>> 
>>>    1. Re: Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR       Transfers
>>>       to Specified Recipients) (Owen DeLong)
>>> 
>>> 
>>> ----------------------------------------------------------------------
>>> 
>>> Message: 1
>>> Date: Fri, 29 May 2015 18:16:34 -0700
>>> From: Owen DeLong <[email protected] <mailto:[email protected]>>
>>> To: Jason Schiller <[email protected] <mailto:[email protected]>>
>>> Cc: "[email protected] <mailto:[email protected]>" <[email protected] 
>>> <mailto:[email protected]>>
>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-2: Modify 8.4
>>>         (Inter-RIR      Transfers to Specified Recipients)
>>> Message-ID: <[email protected] 
>>> <mailto:[email protected]>>
>>> Content-Type: text/plain; charset="utf-8"
>>> 
>>> If it were enforceable, it would address my concern.
>>> 
>>> The problem is that we are then looking to have an ARIN contract enjoin an 
>>> action by the organization in another RIR which I am not sure would give us 
>>> any recourse whatsoever were that contract to be violated.
>>> 
>>> That?s why I didn?t propose language? I don?t think the issue in question 
>>> can be unilaterally addressed, so I think we should accept that and those 
>>> that are interested can begin work on a globally coordinated policy if they 
>>> desire to do so.
>>> 
>>> We?ve already seen that attempting to unilaterally influence minimum policy 
>>> requirements on other regions is unlikely to work. Witness RIPEs recent 
>>> ?workaround? to ?compatible needs basis?. I am not especially interested in 
>>> expanding this problem space.
>>> 
>>> Owen
>>> 
>>> > On May 29, 2015, at 12:06 PM, Jason Schiller <[email protected] 
>>> > <mailto:[email protected]>> wrote:
>>> >
>>> > Owen,
>>> >
>>> > So does this text cover your proposal then?
>>> >
>>> > Draft Policy ARIN-2015-2
>>> > Modify 8.4 (Inter-RIR Transfers to Specified Recipients)
>>> >
>>> > Date: 26 May 2015
>>> >
>>> > Problem Statement:
>>> >
>>> > Organizations that obtain a 24 month supply of IP addresses via the
>>> > transfer market and then have an unexpected change in business plan
>>> > are unable to move IP addresses to the proper RIR within the first 12
>>> > months of receipt.
>>> >
>>> > Policy statement:
>>> >
>>> > Replace 8.4, bullet 4, to read:
>>> >
>>> > "> 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 restriction does not include a transfer to a wholly owned
>>> >         subsidiary out side of the ARIN service region
>>> >         if the recipient org will be required to not transfer any IP space
>>> >         for the remaining balance of 12 month window."
>>> >
>>> >
>>> > On Fri, May 29, 2015 at 4:06 AM, Owen DeLong <[email protected] 
>>> > <mailto:[email protected]> <mailto:[email protected] 
>>> > <mailto:[email protected]>>> wrote:
>>> >
>>> >> On May 28, 2015, at 6:46 AM, Jason Schiller <[email protected] 
>>> >> <mailto:[email protected]> <mailto:[email protected] 
>>> >> <mailto:[email protected]>>> wrote:
>>> >>
>>> >> Owen,
>>> >>
>>> >> How does that differ from the policy text I sent?
>>> >>
>>> >> Can you send an idea of policy text?
>>> >>
>>> >> I thought the text I sent said that an ARIN org can transfer IPs out to 
>>> >> another wholely owned subsidiary in another RIR region if they have been 
>>> >> the recipient of transfer in less that 12 months IF the recipient org 
>>> >> will be required (read by recipient's RIR policy) to hold the transfered 
>>> >> resource for the balance of the 12 months.
>>> >>
>>> >>
>>> > Your proposal allows substitution.
>>> >
>>> > ARIN->Other RIR space A
>>> > Space B Other RIR-> Money/etc.
>>> >
>>> > I want to see substitution transfers prohibited.
>>> >
>>> > Owen
>>> >
>>> >> ___Jason
>>> >>
>>> >> On May 28, 2015 8:31 AM, "Owen DeLong" <[email protected] 
>>> >> <mailto:[email protected]> <mailto:[email protected] 
>>> >> <mailto:[email protected]>>> wrote:
>>> >> Or simply not permit it under ARIN policy until such exists.
>>> >>
>>> >> Owen
>>> >>
>>> >> > On May 28, 2015, at 1:49 PM, John Curran <[email protected] 
>>> >> > <mailto:[email protected]> <mailto:[email protected] 
>>> >> > <mailto:[email protected]>>> wrote:
>>> >> >
>>> >> > On May 27, 2015, at 11:39 PM, Owen DeLong <[email protected] 
>>> >> > <mailto:[email protected]> <mailto:[email protected] 
>>> >> > <mailto:[email protected]>>> wrote:
>>> >> >>
>>> >> >> My suggestion is that I don't mind (virtually) unrestricted moves of 
>>> >> >> addresses to different regions staying with the same organization. 
>>> >> >> However, if we are to allow that, I want us to find a way that you 
>>> >> >> can't merely use that as a way to move addresses out of flip 
>>> >> >> protection to then flip them to another organization via an RIR with 
>>> >> >> a less restrictive transfer policy.
>>> >> >>
>>> >> >> So... If you transfer addresses to another region, keeping them in 
>>> >> >> the same organization, no penalty. However, you are not allowed to 
>>> >> >> subsequently transfer them (or other addresses in that region) to an 
>>> >> >> external party for at least 12 months.
>>> >> >
>>> >> > That second portion that you seek would affect the ongoing operation of
>>> >> > another RIR, i.e. it requires them having some explicit policy to that 
>>> >> > effect.
>>> >> >
>>> >> > To obtain the result you seek, we either need globally coordinated 
>>> >> > transfer
>>> >> > policy in this area, or you need to make the inter-RIR transfer policy 
>>> >> > explicit
>>> >> > in this regard in determination of compatibility.
>>> >> >
>>> >> > /John
>>> >> >
>>> >> > John Curran
>>> >> > President and CEO
>>> >> > ARIN
>>> >> >
>>> >> >
>>> >> >
>>> >> >
>>> >>
>>> >
>>> >
>>> >
>>> >
>>> > --
>>> > _______________________________________________________
>>> > Jason Schiller|NetOps|[email protected] <mailto:[email protected]> 
>>> > <mailto:[email protected] <mailto:[email protected]>>|571-266-0006 
>>> > <tel:571-266-0006>
>>> >
>>> 
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