In my buy-merger-sell experience, most companies don't complete transfers post M&A because they dont want to deal with ARIN. It's not worth the difficulty. Accuracy of the registry suffers again.
Best, Martin On Thursday, March 20, 2014, Sweeting, John <john.sweet...@twcable.com> wrote: > Hi David > > I usually do not weigh in on active policy proposals but I did want to > point out that a lot companies do not complete transfers during M&A > activities simply because they do not have the resources to do so. The one > (or half) person they have dealing with IP resources usually cannot even > keep up with normal workload, let alone the additional workload associated > with M&A activity. At least that has been my experience over many years and > more than a few M&A events. > > Sent from my iPhone > > > On Mar 20, 2014, at 4:51 PM, "David Huberman" < > david.huber...@microsoft.com> wrote: > > > > In contrast to my friend Owen, not only do I believe there is a very > serious issue, but I believe this > > proposal is necessary for ARIN to have any hope of being relevant in the > years to come. I don't > > mean to use that kind of hyperbole, but the issue is very real from my > viewpoint. Allow me to > > explain. > > > > There are two different problems which this policy proposal solves. > > > > 1. Whois accuracy > > ============= > > > > As an ARIN Hostmaster for 10 years, I saw a very high rate of legitimate > transfers which were > > abandoned by the requestor. In turn, Whois did not get updated, and in > most cases, remains > > out of date today. > > > > Think about that for a moment please: legitimate M&A activity occurred, > but Whois never > > got updated. That's a failure of the system. Why does it fail? > > > > The common scenario is straight forward: > > > > 1. Company A buys company B. > > 2. Company A submits a transfer request to ARIN to have the IP > address and AS number > > registrations reflect that Company A is now the registrant. > > 3. ARIN starts asking questions about the utilization of the > number resources. > > 4. Company A walks away from the transfer and never returns. > > > > Step 3 is the consistent problem. In many cases, Company A never even > submits the transfer > > request because they are scared off by step 3. In some cases, it's > because they don't KNOW > > how the IP addresses are being used. In some cases, some IP addresses > are used, and others > > are not, and they think that if ARIN finds that out, they are going to > take the addresses away. > > In some cases, none of the addresses are used. But Company A is > expanding their network > > (or plans to) and wants to use the IP addresses of Company B which they > now own. > > > > Current policy does not work for these common scenarios. I conclude > that having seen > > thousands of transfers cross through the ARIN ticket system and talked > to these requestors > > over the phone for 10 years. > > > > The takeaway from the above is that Whois is not accurate, in part > because ARIN policy > > demands justification for addresses which, regardless of whether Whois > is updated or not, > > Company A is going to use. > > > > In December, the PPML list requested metrics from ARIN staff to show the > extent of abandoned > > transfers. The metrics provided were as follows: > > > > === 8.2 Transfer Request Stats > > > > 2011: > > > > 422 8.2 transfers requested > > 226 8.2 transfers approved (54%) > > 209 8.2 transfers completed (50%) > > > > 2012: > > > > 451 8.2 transfers requested > > 264 8.2 transfers approved (59%) > > 241 8.2 transfers completed (53%) > > > > 2013 YTD: > > > > 445 8.2 transfers requested > > 280 8.2 transfers approved (63%) > > 269 8.2 transfers completed (60%) > > > > If you review the thread in December, these stats generated a lot of > discussion. I am among > > the many who believe that a 40% abandonment rate FOR LEGITIMATE M&A > ACTIVITY belies > > a shortcoming in ARIN policy. There's a barrier that must be removed, > and my experience > > teaches me that it is the utilization requirements of NRPM 8.2. > > > > Now to the second problem. > > > > > > 2. Conflict with the RSA: > > ================== > > > > John Curran can give a more accurate and nuanced history, but as best I > can recall, ARIN > > tried to bring more legacy registration holders into the registry system > by offering a > > Legacy Registration Services Agreement. One of the takeaways from that > initial effort > > was that legacy registration holders were unwilling to sign any > agreement which technically > > allowed ARIN to de-register address space that they had without their > consent. > > > > One of the concessions made over time was language in the RSA documents > which > > removed that concern; it prohibits ARIN from forcibly taking away space > when the > > signer is in compliance with the other terms and conditions of the > contract. > > > > This new language, however, directly conflicts with the plain language > of the NRPM 8.2 > > paragraph that this policy proposal seeks to remove.<This E-mail and any > of its attachments may contain Time Warner Cable proprietary information, > which is privileged, confidential, or subject to copyright belonging to > Time Warner Cable. This E-mail is intended solely for the use of the > individual or entity to which it is addressed. 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