Hi Erik,
Il 23/10/2016 18:06, Erik Bais ha
scritto:
I’ll entertain your question here, although the question isn’t in relation to the policy proposal, but more about how transfers work .. If a company splits… it is actually very simple … you setup a second LIR .. ( Provided that we are talking about RIPE PA space.. ) … And you transfer the space out that needs to go to the business that is split off, to the new LIR … The new entity / LIR would also receive a free /22 IPv4 and have the right to a /29 IPv6 and request an AS number, if they like, in the process … And also get 2 free access tickets to the next RIPE meeting … and may send employees to a new LIR training. In case you are talking about RIPE PI space .. it is even easier .. You decide who the sponsoring LIR is going to be for the new entity.. ( the split off business.. ) Sign an End-User Agreement with the Sponsoring LIR of choice .. Initiate a transfer to split the original prefix into multiple smaller prefixes.. and divide them between the 2 companies.. Send a signed Transfer agreement document and a copy of the End-User Agreement to the RIPE NCC or upload it through the portal … The new entity doesn’t have any additional rights to an extra /22 or other stuff or free tickets or trainings. Similar as with Legacy space .. only a Confirmation of Transfer to the RIPE NCC Service Region ( no RIPE NCC or Sponsoring LIR contract required even .. ) I’m not saying that there might be corner cases out there that one might bump into however I think that with all the different versions that we worked on, we addressed the ones that are common in normal business practices. The policy proposal doesn’t limit companies from doing M&A’s … and if you would read point 2.2, it clearly points that out in the text.. The text states :Scarce resources, which are understood as those resources that are allocated or assigned by the RIPE NCC on a restricted basis (such as IPv4 or 16-bit ASNs), cannot be transferred for 24 months from the date the resource was received by the resource holder. This restriction also applies if the resource was received due to a change in the organisation’s business (such as a merger or acquisition).This restriction does not prevent the resources from being transferred due to further mergers or acquisitions within the 24-month period.So it doesn't prevent future M&A's .. as that is not possible to restrict and not the intention ... The intention is to avoid speculation by hoarding and combining LIR's and transferring IP space out.
I wanted to see this stated in the summary proposal as a goal.
I confess this proposal see me almost neutral but what I don't like is that the summary proposal has as primary goal collect transfer policies in one document
but we are mosltly discussing possibile abuses of M&A procedures.
This policy technically forces business process to take place (this makes this policy similar to 2016-03) as example to keep an LIR opened while the company has been acquired.
In my point of view is not a good idea to force business processes for reasons already expresses by others: future inconsistence of database, possible back market behind
and so on....
Please consider me neutral today i have to think a little bit more about it and maybe need some chat with you.
Said this, text of 2015-04 is wonderfully clean now and is very clear. Thank you for you work Erik.
Now I need to go get the plane to get there ;-)
see you in Madrid.
regards
Riccardo
Regards, Erik Bais --- Van: address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] Namens Ciprian Nica Verzonden: zaterdag 22 oktober 2016 22:39 Aan: Radu-Adrian FEURDEAN ripe-wgs@radu-adrian.feurdean.net CC: RIPE Address Policy WG List <address-policy-wg@ripe.net> Onderwerp: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies) That's a good point, what would happen when a business splits ? I think there are many situations that need to be discussed and if we want to do something good we'd need to cover all situations. And yes, there is definitely the need for better policies in order for NCC to do exactly what the community wants and not leave room for interpretation. Ciprian On Sat, Oct 22, 2016 at 11:33 PM, Radu-Adrian FEURDEAN <ripe-wgs@radu-adrian.feurdean.net> wrote: On Fri, Oct 21, 2016, at 13:42, Sascha Luck [ml] wrote:RIPE NCC recognises that and puts M&A firmly outside policy. Where it should remain unless the desire is that every transfer application or M&A notification start with filing suit against the NCC.On the other hand, since RIPE NCC *DOES* allow multiple LIRs per single legal entity, it would make some sense that the M&A procedure (the one outside the policy scope) is limited to only changing the name of the LIR. Of course that would mean that all movements of IP addresses between LIRs, even those related to mergers, acquisition, restructuring, consolidation, ..... would fall under transfer policy. Could someone detail what would be the problem in this case (except a limited amount of money of up to 4200 EUR). Unfortunately this is not where we are, and it doesn't look like it's where is going. As for RIPE NCC handling completely on its own the M&A process this is exactly what allowed abuse to happen in the first place (and will still do, even with 2015-01, 2015-04 and 2016-03). And how about a business split - this doesn't feel like handled by the M&A procedure. -- Radu-Adrian FEURDEAN
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Ing. Riccardo Gori e-mail: rgori@wirem.net Mobile: +39 339 8925947 Mobile: +34 602 009 437 Profile: https://it.linkedin.com/in/riccardo-gori-74201943
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