On 11 Jun 2015 13:57, "Garry Glendown" <garry@nethinks.com> wrote:

>> I will readily admit that I can not come up with a text which prevents
>> abuse _and_ allows for valid operational needs, though.
> Indeed. Mergers & acquisitions are real-world business events that APWG
> cannot affect. I see a big nut to crack on how to address abuse via
> "illegitimate" M&A, including figuring out what is and what is not
> "illegitimate" and "abuse".
I reckon if/when this proposal has gone through (either confirmed or
rejected), some sane solution to this whole thing has to be found ... as
several people - even some nay-sayers - have said, the current proposal
does not cover enough bases to discourage or prevent policy abuse.

I'm sure that - as it has a direct impact on the business of both
IP-brokers and wannabe-profiteers - it will face even stronger
opposition by several people, but most likely no substantial arguments
(as we have already seen these last couple days - after all, saying "it
will cut in my personal profit" won't be a valid argument against the
policy to knowingly cut into profits of policy-abusers in order to allow
late entries into the ISP market some affordable set of IPv4 addresses).

Without really thinking about all possibilities, I would imagine there
are certain reasons for or against the transfer of IPs, though some
wording and "way of proof" would have to be found that be used to decide
whether a transfer was permitted or not ...

>From the top of my head, for a transfer, certain situations come to mind:

* merger/acquisition of company (can be proved through official
papers/registration information)
* is there actually any other justifiable reason?

Personally, I would see certain use cases where a transfer is not
necessary for any technical/organizational reasons: (which may even
weigh stronger than e.g. the merger/acquisition argument)

* shutdown of an ISP or company, where loss of IP usage would not impact
customers (current use is terminated, IPs are no longer announced)
* IPs were never (publicly?) used or only intermittently announced (how
could actual use be documented apart from just an announcement? Would an
announcement on the Internet be sufficient?), or have been unused for a
certain amount of time (3 months?)

Due to the fact that IP addresses (especially PAs assigned to an LIR)
are not "owned" by the LIR (in part documented by the yearly bill for
the resource) IPs should not count as an asset with monetary value, thus
allowing the RIR to collect them if policy requirements aren't met.

Possibly: Requirement to announce and use IPs from last-/8 within 3
months of assignment, otherwise the non-transferal-duration would be
extended by 1 year

*putting on flame-resistant armor*

-garry