And people wonder why most M&A goes unrecorded in whois...

Matthew Kaufman

(Sent from my iPhone)

> On Jul 23, 2014, at 6:28 PM, John Curran <jcur...@arin.net> wrote:
> 
>> On Jul 23, 2014, at 8:28 PM, Scott Leibrand <scottleibr...@gmail.com> wrote:
>> 
>> Ok, I think I understand what you're concerned about.  But I think that's a 
>> different issue, which isn't caused by a conflict with the NRPM, but rather 
>> is caused by ARIN's operational practice (correct me if I'm wrong, John) of 
>> requiring 50% utilization of acquired space to complete an 8.2 transfer.  
>> Maybe it would be useful if ARIN staff could detail what the operational 
>> practice is in the case of an 8.2 transfer request of dramatically 
>> underutilized space?
> 
> Scott -
> 
> If the combined resources of an NRPM 8.2 transfer appear less than 50% 
> utilized, we ask for their 
> 3, 6 and 12 month projections and as long as they show projected usage of at 
> least 50% of the 
> block within one year, we approve the transfer.  If they don't project at 
> least 50% utilization within 
> one year, we work with them to return or transfer space to come into 
> compliance.
> 
> We use the 50% utilization criteria which is presently documented in the end 
> user policy, as that 
> is the most generous interpretation of the NRPM 8.2 language (i.e. "justified 
> under ARIN policy") 
> available.  Adoption of ARIN-2014-9 as written would not change this 
> practice, only make clear 
> that we are not reclaiming blocks in this situation.
> 
> Thanks!
> /John
> 
> John Curran
> President and CEO
> ARIN
> 
> 
> 
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