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 <o...@delong.com> 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 <muel...@syr.edu> 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: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
>> Behalf Of Rudolph Daniel
>> Sent: Saturday, May 30, 2015 5:49 PM
>> To: arin-ppml@arin.net
>> 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, <arin-ppml-requ...@arin.net> wrote:
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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 <o...@delong.com>
>> To: Jason Schiller <jschil...@google.com>
>> Cc: "arin-ppml@arin.net" <arin-ppml@arin.net>
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-2: Modify 8.4
>>         (Inter-RIR      Transfers to Specified Recipients)
>> Message-ID: <8a9f435e-20bf-4e90-9141-99a7d93fc...@delong.com>
>> 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 <jschil...@google.com> 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 <o...@delong.com 
>> > <mailto:o...@delong.com>> wrote:
>> >
>> >> On May 28, 2015, at 6:46 AM, Jason Schiller <jschil...@google.com 
>> >> <mailto:jschil...@google.com>> 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" <o...@delong.com 
>> >> <mailto:o...@delong.com>> wrote:
>> >> Or simply not permit it under ARIN policy until such exists.
>> >>
>> >> Owen
>> >>
>> >> > On May 28, 2015, at 1:49 PM, John Curran <jcur...@arin.net 
>> >> > <mailto:jcur...@arin.net>> wrote:
>> >> >
>> >> > On May 27, 2015, at 11:39 PM, Owen DeLong <o...@delong.com 
>> >> > <mailto:o...@delong.com>> 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|jschil...@google.com 
>> > <mailto:jschil...@google.com>|571-266-0006
>> >
>> 
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