I got that idea from the use of the word "unused" on 
https://www.arin.net/resources/transfers/index.html


IPv4 address space and Autonomous System Numbers (ASNs) issued by ARIN or its 
predecessors may only be transferred to another organization when:
        • An organization acquires the assets that are using IPv4 addresses 
and/or ASNs in a currently operating network via a merger, acquisition, or 
similar transaction
        • An organization with unused IPv4 address space or an ASN releases it 
to a specified recipient who qualifies for it under current ARIN policy



(Note also the "may only" part.)


On that same page,


TRANSFERS TO SPECIFIED RECIPIENTS 
(NRPM 8.3)

If your organization is in need of, or currently holds unused ARIN-issued IPv4 
address space or an Autonomous System Number (ASN) you may request an 8.3 
Transfer (Transfer to Specified Recipients within the ARIN Region) transfer.


I guess what you are saying is that the "unused" part is unused in operation.  
:-)



Btw,  There are also mentions of "unused" at the APNIC site.

https://cgi1.apnic.net/assets/apnic/js/apps/transfers/Transfer%20procedure%20of%20unused%20IPv4%20and%20AS%20Numbers%20between%20APNIC%20accounts.pdf
https://www.apnic.net/services/become-a-member/manage-your-membership/transfer-resources#unused
https://www.apnic.net/services/become-a-member/manage-your-membership/transfer-resources


--Sandy

On Mar 22, 2015, at 11:05 PM, John Curran <[email protected]> wrote:

> On Mar 22, 2015, at 3:48 PM, Sandra Murphy <[email protected]> wrote:
>> 
>> Interesting answer.  John, my understanding of what I've read on the ARIN 
>> web site about transfer was that address space to be transferred had to be 
>> unused.
>> 
>> Did I read wrong?
> 
> There is no requirement that the address block be "unused"
> (in either sense, i.e. not assigned to devices or not routed)
> 
> /John
> 
> 
> 
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