I would argue that 257 probably represents a significant fraction of the distributed portion of 103/8. I would be interested if staff can answer what percentage of the issued 103/8 resources have been subject to one or more M&A transfers since issuance. I’d be especially interested in the number instances where the same entity has “acquired” more than entity that holds 103/8 block(s). I am concerned that there could be an emerging pattern of: 1. Stand up shell entity 2. Subscribe shell entity to APNIC and obtain 103/8 block. 3. Merge shell entity into parent entity and M&A transfer block into parent’s holdings. 4. Lather, rinse, repeat. Owen
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