Dear all, as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware. I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy. Kind regards, Remco
Please, go to https://ripe72.ripe.net/live/main/ . There is discussion about IPv4 proposals now. 2016-05-25 10:52 GMT+03:00 Remco van Mook <remco.vanmook@gmail.com>:
Dear all,
as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware.
I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy.
Kind regards,
Remco
-- ---------- Best regards, Aleksey Bulgakov Tel.: +7 (926)690-87-29
Dears, as mentioned during the policy session, I am opposing to this (version of) the policy proposal. While I was sure that I did voice this concern over the mailing list, I can not find the e-mail now. But I am sure I did voice this concern and the opposition at previous RIPE Meeting(s). As long as this proposal adds the 2 years holding period of scarce resources moved through M&As (which are 'regulated' through a RIPE NCC procedure) I will oppose to it. I am not going to go into examples wars of why some company would want to transfer/move/merge/etc.. resources within a 2 years period. While I agree that transfers should have a holding (or call it anti-flip) period and I even proposed 2015-01 (which is now part of policy), I do not agree that we should include M&As in the same bucket. If a new version of this policy proposal would be only about transfers of IP addresses, and not try to sneak in M&As into the same document, I would agree with it. my 2 cents, elvis On 5/25/16 9:52 AM, Remco van Mook wrote:
Dear all,
as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware.
I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy.
Kind regards,
Remco
-- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer E-mail: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> Mobile: +1 (702) 970 0921 Recognised IPv4 Broker/Facilitator in:
Hi Elvis, I oppose to your word choice that we are trying to sneak something in, with this policy. As stated during the discussion at the AP, a change to the holdership will to fall under the same restrictions as the transfers currently, that was pointed out AND discussed since version 1. If a company is currently doing a M&A after that particular company has become a (new) LIR since 6 months, it means it needs to keep the LIR open for another 18 months.. For any M&A, the cost for a membership fee of 18 months will not be a deal breaker for an actual business take-over … unless one is trying to game the system. To give an indication, the damage of a diner with 7 people at the MASH Penthouse at the RIPE72 venue can be more expensive ... Thanks for the feedback. Regards, Erik Bais Van: address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] Namens Elvis Daniel Velea Verzonden: woensdag 25 mei 2016 10:28 Aan: address-policy-wg@ripe.net Onderwerp: Re: [address-policy-wg] opposition to 2015-04 Dears, as mentioned during the policy session, I am opposing to this (version of) the policy proposal. While I was sure that I did voice this concern over the mailing list, I can not find the e-mail now. But I am sure I did voice this concern and the opposition at previous RIPE Meeting(s). As long as this proposal adds the 2 years holding period of scarce resources moved through M&As (which are 'regulated' through a RIPE NCC procedure) I will oppose to it. I am not going to go into examples wars of why some company would want to transfer/move/merge/etc.. resources within a 2 years period. While I agree that transfers should have a holding (or call it anti-flip) period and I even proposed 2015-01 (which is now part of policy), I do not agree that we should include M&As in the same bucket. If a new version of this policy proposal would be only about transfers of IP addresses, and not try to sneak in M&As into the same document, I would agree with it. my 2 cents, elvis On 5/25/16 9:52 AM, Remco van Mook wrote: Dear all, as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware. I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy. Kind regards, Remco -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer E-mail: elvis@V4Escrow.net <mailto:elvis@V4Escrow.net> Mobile: +1 (702) 970 0921 Recognised IPv4 Broker/Facilitator in:
Hi Erik, On 5/30/16 1:45 AM, Erik Bais wrote:
Hi Elvis,
I oppose to your word choice that we are trying to sneak something in, with this policy.
As stated during the discussion at the AP, a change to the holdership will to fall under the same restrictions as the transfers currently, that was pointed out AND discussed since version 1.
that was my mistake, I was sure I had pointed it out in an older e-mail.. can't find it so it probably never made it to the list and was in draft status forever :)
If a company is currently doing a M&A after that particular company has become a (new) LIR since 6 months, it means it needs to keep the LIR open for another 18 months..
For any M&A, the cost for a membership fee of 18 months will not be a deal breaker for an actual business take-over … unless one is trying to game the system.
well, this is what I was opposing to. However, after further discussions offline, I no longer think this is quite such a bad idea. So, I no longer oppose.
To give an indication, the damage of a diner with 7 people at the MASH Penthouse at the RIPE72 venue can be more expensive ...
you never invited me there... I would've wanted to see the proof.
Thanks for the feedback.
so, +1 to the proposal. cheers, elvis
Regards,
Erik Bais
*Van:*address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] *Namens *Elvis Daniel Velea *Verzonden:* woensdag 25 mei 2016 10:28 *Aan:* address-policy-wg@ripe.net *Onderwerp:* Re: [address-policy-wg] opposition to 2015-04
Dears,
as mentioned during the policy session, I am opposing to this (version of) the policy proposal.
While I was sure that I did voice this concern over the mailing list, I can not find the e-mail now. But I am sure I did voice this concern and the opposition at previous RIPE Meeting(s). As long as this proposal adds the 2 years holding period of scarce resources moved through M&As (which are 'regulated' through a RIPE NCC procedure) I will oppose to it.
I am not going to go into examples wars of why some company would want to transfer/move/merge/etc.. resources within a 2 years period. While I agree that transfers should have a holding (or call it anti-flip) period and I even proposed 2015-01 (which is now part of policy), I do not agree that we should include M&As in the same bucket.
If a new version of this policy proposal would be only about transfers of IP addresses, and not try to sneak in M&As into the same document, I would agree with it.
my 2 cents, elvis
On 5/25/16 9:52 AM, Remco van Mook wrote:
Dear all,
as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware.
I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy.
Kind regards,
Remco
--
Elvis Daniel Velea
Chief Executive Officer
E-mail:elvis@V4Escrow.net <mailto:elvis@V4Escrow.net> Mobile: +1 (702) 970 0921
Recognised IPv4 Broker/Facilitator in:
On Mon, May 30, 2016 at 12:45:31AM +0200, Erik Bais wrote:
As stated during the discussion at the AP, a change to the holdership will to fall under the same restrictions as the transfers currently, that was pointed out AND discussed since version 1.
The fact remains that policy has no business regulating into the business transactions of members (vulgo M&A) and I oppose it for that reason alone. rgds, Sascha Luck
Hi Sasha,
The fact remains that policy has no business regulating into the business transactions of members (vulgo M&A) and I oppose it for that reason alone.
RIPE policy does regulate IP allocations and under what conditions you are allowed to have/transfer/etc them. I agree that RIPE policy cannot regulate an organisation's M&A itself, but what happens to IP allocations when M&A happens definitely is in scope. Not expressing any opinion in favour or against, just clarifying scope :) Cheers, Sander
On Mon, May 30, 2016 at 05:44:05PM +0200, Sander Steffann wrote:
RIPE policy does regulate IP allocations and under what conditions you are allowed to have/transfer/etc them. I agree that RIPE policy cannot regulate an organisation's M&A itself, but what happens to IP allocations when M&A happens definitely is in scope.
RIPE policy has, until recently, explicitly recognised that M&A (and what happens to resources due to those) is not in scope for the PDP. It is only since "last /8" that certain elements of the "community" have tried, by hook or by crook, to arrogate themselves the right to decide what happens to resources in the event of M&A. rgds, Sascha Luck
Not expressing any opinion in favour or against, just clarifying scope :)
Cheers, Sander
Hi Sasha,
RIPE policy has, until recently, explicitly recognised that M&A (and what happens to resources due to those) is not in scope for the PDP. It is only since "last /8" that certain elements of the "community" have tried, by hook or by crook, to arrogate themselves the right to decide what happens to resources in the event of M&A.
It has always been in scope, it just hasn't been very interesting to write policy about. Until now when people are using it as a way to circumvent policy. Cheers, Sander
Hi, On Mon, May 30, 2016 at 05:53:10PM +0100, Sascha Luck [ml] wrote:
RIPE policy has, until recently, explicitly recognised that M&A (and
"explicitly" implies that this has been, uh, explicitly written down somewhere. Could you provide a reference? Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279
On Mon, May 30, 2016 at 06:55:03PM +0200, Gert Doering wrote:
"explicitly" implies that this has been, uh, explicitly written down somewhere. Could you provide a reference?
I was sure I'd read an explicit declaration that transfers due to business transactions do not fall under transfer policies in one of the alloc/assignment policy docs, however I might have been wrong and was thinking of ripe-654 which is a Organisational Document. This document, in sec 2.0 recognises transfers thus: A member must inform the RIPE NCC ifone or bothof the following changes occurs: Internet Number Resource are transferred. Such transfers may take place: Because of a change in the members business structure, for example in the case of a merger or acquisition of the members organisation. In the case of a transfer of Internet number resources from the member to another party according to RIPE Policies (section 5.5 and 6.4 of IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region , section 8 of IPv6 Address Allocation and Assignment Policy and section 4.0 of Autonomous System (AS) Number Assignment Policies ). Such a transfer may also be facilitated through the RIPE NCC Listing Service . The member changes its official legal name . Such a change may occur, for example, because of a merger or acquisition of the members organisation. So there are transfers due to M&A, name changes, and *according to transfer policy*. Three separate cases. Which also means that 2015-04, stating explicitly that M&A transfers are subject to policy, contradicts ripe-654 and would trigger a change of this document - which I hope would be subject to membership approval via GM vote. rgds, Sascha Luck
On Mon, May 30, 2016, at 20:31, Sascha Luck [ml] wrote:
So there are transfers due to M&A, name changes, and *according to transfer policy*. Three separate cases.
Which also means that 2015-04, stating explicitly that M&A transfers are subject to policy, contradicts ripe-654 and would trigger a change of this document - which I hope would be subject to membership approval via GM vote.
Hi, Well, actually, to my understanding, the M&A procedure already changed without vote from the membership. The whole issue is "what is a merger or an acquisition". To my current understanding: - Company A purchased 100% of company B parts/shares/equity -> NOT M&A - Company A purchased assets of company B including network and customer base -> YES M&A - Company A and company B merge (join their assets under a common entity) -> YES M&A - Company X changing name (irrelevant of reason) -> "name change" (ripe-645 section 4.0) - Merging LIRs from the same company -> NO LONGER M&A (which changed without any vote), or am I wrong ? Concerning, the proposal, there is the very confusing section 2.2 for which says two seemingly conflicting things. The best I can understand (which seems to be confirmed by the impact analysis) is that the 24 months interval is reset by a M&A, but M&A is not subject to it. Whatever M&A means, which is still out of policy's scope. The wording of section 2.2 is my only issue, but I suppose it is a minor one (how easy to read/understand a policy is, does not seem to be an issue). Basically, no real impact on M&A (again, whatever that means). -- Radu-Adrian FEURDEAN fr.ccs
Thanks Remco. We'll take your suggestion in mind before moving to last call. Regards, Erik Bais -----Oorspronkelijk bericht----- Van: Remco van Mook [mailto:remco.vanmook@gmail.com] Verzonden: woensdag 25 mei 2016 9:53 Aan: address-policy-wg@ripe.net CC: Erik Bais <erik@bais.name> Onderwerp: opposition to 2015-04 Dear all, as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware. I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy. Kind regards, Remco
participants (9)
-
Aleksey Bulgakov
-
Elvis Daniel Velea
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Elvis Daniel Velea
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Erik Bais
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Gert Doering
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Radu-Adrian FEURDEAN
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Remco van Mook
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Sander Steffann
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Sascha Luck [ml]