Dear Aleksey and all, We would like to clarify the situation because the policy refers to transfers between RIPE NCC members and not transfers between the LIR accounts that members might hold. A member may hold multiple LIR accounts. Regarding the section that you refer to in the procedure, please see the mail that was sent to the NCC Announce mailing list in October: https://www.ripe.net/ripe/mail/archives/ncc-announce/2018-October/001286.htm... This message explains how the RIPE NCC processes transfers of IPv4 address space or 16-bit ASNs due to a merger, acquisition or any other change in business structure. We hope this clarifies that no policy violation has taken place. A merger or acquisition is possible at any time and must take place following the processes outlined in the email. Kind regards, Marco Schmidt Policy Officer RIPE NCC On 17/12/2018 19:21, Aleksey Bulgakov wrote:
Hi.
Regarding our situation. We have 3 accounts opened this year (for different legal entities). We provided the oficial government documents that confirm M&A procedure. But the NCC doesn't want to merge 2 accounts (of closed organizations) into the 1st account due to it is necessary to convert such accounts into additional account of receiving party, regarding https://www.ripe.net/publications/docs/ripe-709#transfer36.
But there is restriction to transfer the resources during 24 month between accounts of the same member. So we should pay for additional 2 years fees. пн, 17 дек. 2018 г. в 21:12, Jens Ott - Opteamax GmbH <ripe@opteamax.de>:
Which is kind of the point. The 24 month restriction holds, unless one LIR gets bought/merged, and the latter needs to be proved by official documents. This is also not correct! At least from my experience, the restriction also persists on being bought!
The difference between being bought and merged is, at least from German legal point of view, that in a merge (=Verschmelzung) the $OLD company does not exist any longer but becomes fully integrated into $NEW company, while in buying a company, $OLD stays it's own legal entit y.
From my experience ONLY A MERGE IS accepted by RIPE to not apply 24month restriction, while being bought does not shorten this restrictio n.
BR
-- Jens Ott Geschäftsführer
Opteamax GmbH
Simrockstr. 4b 53619 Rheinbreitbach
Tel.: +49 2224 969500 Fax: +49 2224 97691059 Email: jo@opteamax.de
HRB: 23144, Amtsgericht Montabaur Geschäftsführer: Jens Ott Umsatzsteuer-ID.: DE264133989