Hi Aftab,
We are dealing with similar problems also in other regions, so regardless if this has been visible or not for the secretariat, the problem exists.
As explained in the problem statement, the actual text (I’m going to speak in a generic way for all the cases, IPv4, IPv6 and ASN), doesn’t clarify if this is only intra-RIR or also intra-RIR. This is the key part.
The actual text doesn’t contemplate the cases related to re-organization of companies (typically big groups), or relocation from one region to another. This is also very important.
Also, doesn’t clarify if this is also acceptable for a partial acquisition. I know this probably is being correctly interpreted by the secretariat, but because the problem indicated in the previous two paragraphs, I’m taking the opportunity to clarify that in the text.
Now, to better understand it, I can present several examples.
- A big multinational operator, working in several regions, has excess of IPv4 addresses in one region (RIR), so is using some of them in another region. With the actual text, it is not clear they can “re-organize” the correct registration of those addresses.
- An operator has business covering transit, service provider and data-centers. They decide to sell only part of it, let’s say the data-centers. So, this is a very clear case for a “partial M&A”, it may be in the same regions or among regions, but there are more complex cases.
- A company has a data center, using VMs in one region, let’s say Europe. They decide to relocate to Asia, with a new company, because they have better business opportunities, or less taxes or lower costs, or whatever. Because all is about VMs, you can do this “on-line”, it will take a few hours/days, this can be done by several means, and when all is done “keep” the VMs in sync and in a few minutes, shut down the old VMs and keep only the new ones, with the original addressing space they had in Europe. Of course, this may be the complete company, or only a division of it (creating a new company).
Please, let me know if this is sufficiently clear.
I’m happy to include those examples in a new version of the policy proposal if that helps.
Regards,
Jordi
De: <sig-policy-bounces@lists.apnic.net> en nombre de Aftab Siddiqui <aftab.siddiqui@gmail.com>
Fecha: viernes, 15 de marzo de 2019, 15:21
Para: Sumon Ahmed Sabir <sasabir@gmail.com>
CC: Policy SIG <sig-policy@apnic.net>
Asunto: Re: [sig-policy] Policy Proposal: prop-130-v001: Modification of transfer policies
If I may ask the author.
- Explain the problem statement.
- Can you provide an example where this "unclear policy of M&A" created a problem?
- Did you ask Secretariat if this is actually a problem? Did they provide any stats?
Regards,
Aftab A. Siddiqui
Dear SIG members,
The proposal "prop-130-v001: Modification of transfer policies"
has been sent to the Policy SIG for review.
It will be presented at the Open Policy Meeting at APNIC 48 in
Chiang Mai, Thailand on Thursday, 12 September 2019.
We invite you to review and comment on the proposal on the mailing list
before the meeting.
The comment period on the mailing list before an APNIC meeting is an
important part of the policy development process. We encourage you to
express your views on the proposal:
- Do you support or oppose this proposal?
- Does this proposal solve a problem you are experiencing? If so,
tell the community about your situation.
- Do you see any disadvantages in this proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more
effective?
Information about this proposal is available at:
http://www.apnic.net/policy/proposals/prop-130
Regards
Sumon, Bertrand, Ching-Heng
APNIC Policy SIG Chairs
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