The main problem I see is that this policy for the first time will open the door up to IPv6 transfers. I do not agree with IPv6 transfers.

Up to this point, the primary reason why we allow transfers of IPv4 and 16 bit ASN numbers is the shortage of these resources.

In the case of IPv6 addresses, there is no shortage, therefore I do not think we need to be going down that road.

If the policy was limited to IPv4 and 16 bit ASN's, I would not have a problem if indeed the business has moved to another region. However, I do not want to see this policy being used for forum shopping. I do not want to see the "I do not like the policies of RIR A, so I am taking my ball (and my numbers) to RIR B"

Albert Erdmann
Network Administrator
Paradise On Line Inc.


On Tue, 18 Jun 2019, Chris Woodfield wrote:

Hello PPML,

The Advisory Council is seeking statements of support or opposition to the 
below draft policy, which so far have not been seen on PPML. I’d advise the 
community to consider the following questions:

1. Is the problem statement a valid and/or likely occurrence that would require 
a change of policy to address?
2. Is the proposed text to address the problem statement a valid means to do 
so? Are there other approaches the community would like the AC to consider?
3. Is there any potential deleterious impact should this language be adopted 
into the NRPM?

We look forward to hearing the community’s response.

Thank you,

-Chris Woodfield
ARIN Advisory Council

On May 21, 2019, at 11:01 AM, ARIN <[email protected]> wrote:

On 16 May 2019, the ARIN Advisory Council (AC) accepted "ARIN-prop-270: Inter-RIR 
M&A" as a Draft Policy.

Draft Policy ARIN-2019-10 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2019_10/

You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate 
the discussion in order to assess the conformance of this draft policy with 
ARIN's Principles of Internet number resource policy as stated in the Policy 
Development Process (PDP). Specifically, these principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The PDP can be found at:
https://www.arin.net/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2019-10: Inter-RIR M&A

Problem Statement:

Merger, acquisition, or reorganization activity sometimes results in a 
restructuring where company resources, the management of number resources, or 
the use of number resources are concentrated outside the ARIN service region. 
In this case it may be desirable for the current legal entity or a legal entity 
that is a parent, child or sister to move the servicing of the number resources 
to a different RIR.

Example:

Imagine a case where a global company has decided to discontinue service in the 
ARIN service region (shuttering ARIN region offices laying off ARIN region 
employees, and canceling ARIN region customers) and repurpose the network 
resources and number resources in the rest of its global footprint.

Imagine a case where a global company has decided to divest its service in the 
ARIN region (selling all ARIN region offices, all ARIN region network assets, 
all ARIN service region customers, all number resources used in the ARIN 
(associated with previous noted sale of network and customers), but retaining 
ARIN issued resources in use outside of the ARIN service region.

Policy Statement:

Add to section 8.2:

When merger, acquisition, or reorganization activity results in surviving legal 
entity that is incorporated outside the ARIN service region, or focused outside 
the ARIN service region, or is merging with an organization that already has a 
relationship with another RIR, then resources may be moved to another RIR in 
accordance with the receiving RIR’s policies.

Comments:

Timetable for implementation: Immediate
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