Hi,

Since there were many discussions and yes, I've made the mistake to write in a different topic about the 2015-04, I want to state clearly that I oppose this policy.

Again, if it would do what it's goal is, then it would be perfect. But it doesn't. It brings up important changes which are commented by people with no experience in mergers and acquisitions.

While working for RCS&RDS I have seen many takovers and acquisitions and I know how the process goes. It's not always easy and definitely complicated. Why do we need to put more stones in front of the wagon ? An acquisition is not just signing a transfer agreement. For regular transfers it's ok to have a 24 months hold period, but asimilating a regular transfer with a company acquisition is wrong. Buying a company needs to be documented with official, state issued, documents. That is if I prove that I legally acquired a company, why would you think that it's something fishy and the purpose was to hide a simple transfer of IPs ? The two are nowhere near to be compared. The acquisition process takes time and money which represents already enough reasons not to mask a transfer this way.

Ciprian

On Thu, Oct 20, 2016 at 11:37 PM, Stefan van Westering <stefan@softtech.nl> wrote:

Hi,

Just like the other proposal (2016-03) i support this proposal and thus:

I say +1 for this proposal.

Again if this is not the right place or need extra motivation to be noted, let me know.

With kind regards,

Stefan van Westering

SoftTech Automatisering B.V.

Op 19 okt. 2016 om 21:04 heeft Sander Steffann <sander@steffann.nl> het volgende geschreven:

Hello Marius,

Thank you for the explanations, but I believe you haven't really addressed the issues I mentioned.

The first issue is ABOUT Transfer Policies, to pay the annual membership fee after you TRANSFER ALL YOUR RESOURCES and maybe even close your Company, is about Transfer Policies.

No, that is about your contractual agreement with the RIPE NCC.

Your second answer is very subjective, have you ever buy and merge Companies? I've done that a couple of times, you never sell the company's (you merge) resources before the merge, because that company doesn't belong to you before the merge and is not you to decide regarding selling anything of that Company resources, either that is IP or fiber optic cable. Is NOT AT ALL what you mention:"First acquiring them only to immediately sell them again is explicitly not allowed by RIPE policy". What this have to do with the situation I mention ??? Please refer to the situation I mention, not on other matters that have nothing to do with it.

This is exactly the situation you mention: you buy a company, acquiring all their assets. One of those assets is an IPv4 allocation from RIPE NCC. To prevent speculation with IPv4 resources it is not allowed to sell those resources within 24 months of acquiring them.

So in your case: buy the company, keep it running as a separate company/LIR for a little while, sort out where you want to transfer the resources you don't need, then merge the companies/LIRs.

So, no problem.
Sander