The concept that the legacy status applies independently to resources or IP addresses, separate from their assignment to a resource holder, seems incorrect. The legacy status applies to the assignment of resources to a resource holder before the creation of the RIRs, but not to the resources or the IP addresses themselves. 

All IPv4 addresses were created at the same time. When they were assigned for use differs; therefore, when they were assigned for use and to whom they are assigned for use is what matters.

When addresses are transferred to a different organization, a new assignment is made, or in other words, they are reassigned. And it seems proper that the new assignment no longer has the legacy status, as they are now assigned to a different organization.

When a merger or acquisition occurs, we also call that a transfer, but it is a transfer to a new version of the same organization, not to a different organization. In this case, it seems propers that the assignment maintains its legacy status, as the same organization, just a different version of the same organization, continues to hold the assignment.  

The legacy status is important and is not a mistake because, as a community, we believe it is important to maintain the uniqueness of the assignments made before the creation of the RIRs. However, at least in my opinion, it is a mistake to believe that the legacy status applies to IP addresses independent of who holds the assignment.

Thank you.
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David Farmer               Email:farmer@umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota  
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
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