I have trouble with both phrases.

Even if the resources are to be re-assigned to organizations or entities which 
do not receive connectivity from the original registrant, I see no reason to 
issue addresses to anyone who will not be using them on an operational network.

Owen


> On Oct 31, 2019, at 3:10 PM, Scott Leibrand <scottleibr...@gmail.com> wrote:
> 
> On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil <k...@openiadvisors.com 
> <mailto:k...@openiadvisors.com>> wrote:
> Dear All,
> 
> Prior to tomorrow's community discussion of Draft Policy ARIN-2019-18, I 
> wanted to offer some clarification and propose some language for 
> consideration to address questions posed on the PPML.
> 
> Regarding the question over the intended meaning of "non-connected networks", 
> I will clarify that I mean this policy to refer to re-assignment to 
> organizations and entities which do not receive connectivity from the 
> original registrant.  
> 
> As such, I wanted to offer the following alternative edit to 8.5.2: 
> 
> 8.5.2 Operational Use
> ARIN allocates or assigns number resources to organizations via transfer 
> primarily for the purpose of use on an operational network, but may allocate 
> or assign number resources to organizations for other purposes, including 
> re-assignment to organizations and entities which do not receive connectivity 
> from the original registrant.
> 
> 
> I believe this is consistent with the intent of 2019-18, and I would support 
> this language.
>  
> 
> 
> Alternatively, and more simply, since the sentence referencing "non-connected 
> networks" starts with "including" and is therefore not meant to be an 
> exclusive "other purpose", but rather illustrative, we can remove it 
> entirely.  That option would read: 
> 
> 8.5.2 Operational Use
> ARIN allocates or assigns number resources to organizations via transfer 
> primarily for the purpose of use on an operational network, but may allocate 
> or assign number resources to organizations for other purposes.  
> 
> I believe this is materially different than the text above, in that it would 
> give ARIN permission to approve transfers for any reason whatsoever. ARIN in 
> the past has interpreted such ambiguity in favor of allowing whatever is not 
> expressly prohibited. As such, I don't think this language accomplishes the 
> original intent, and would oppose it.
> 
> -Scott
>  
> *please note that the online version of the policy proposal reads "solely 
> primarily" instead of "primarily".  This is a typo due to originally 
> proposing the language with the word "solely" in strike-through text 
> (solely), which did not translate.  
> 
> Further, I want to clarify, as the original author of the proposal, that the 
> key intent of the policy is to acknowledge that small and medium-sized 
> businesses have a need for IPv4 space, but often cannot afford to buy space 
> in the current market.  Legitimizing a subleasing market increases 
> accessibility to IPv4 space, and opens the market to business solutions to 
> facilitate safe, trusted subleasing practices, including keeping the correct 
> registry updated.  
> 
> Thanks all for the continued discussion.  
> 
> Best,
> 
> Kiran
> -- 
> Kiran Malancharuvil
> Open-i Advisors      
> p:  415 419 9138
> http://openiadvisors.com 
> <http://openiadvisors.com/>_______________________________________________
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