On Thu, Jan 30, 2014 at 12:13 PM, David Huberman
<[email protected]> wrote:
> 1) There are unanticipated consequences of the anti-flip language
> that make it impossible for companies to both be truthful with
> ARIN and to move blocks where they need to be.

Hi David,

You're not wrong. But here's the thing: bad policy may give folks
incentive to lie, but unfair policy gives them the excuse to do so
with a clear conscience. That's why inconsistent regulation is
generally worse than merely bad regulation. Regulation which is merely
bad at least has the virtue of being an equal opportunity offender.

My feel is that we should either dump the anti-flipping language... or
not. Creating loopholes will just make a bad design worse.

You can make a reasonable argument that a registry transfer where the
resources stay with the exact same registrant doesn't materially
change the policy. It's not a loophole. But adding "and subsidiaries"
makes an end-run around 8.2/8.3.

Regards,
Bill Herrin


-- 
William D. Herrin ................ [email protected]  [email protected]
3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
Falls Church, VA 22042-3004
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