[ncc-services-wg] Single-purpose "LIRs"

Dear Daniel,

Thank you for your email.

Section 3.1 of the RIPE NCC procedural document, "Transfer of Internet
Number Resource Records and Change of a Member’s Official Legal Name",
details the information and documentation we need to see before
proceeding with a transfer of resources. In particular, it mentions that
the RIPE NCC will ask for the following information:

"ii. A description of the reason for the transfer (for example, due to
merger, acquisition, transfer of allocation according to the RIPE policies)

If the transfer is taking place due to a change in the structure of the
organisation(s) involved, a description of the changes among the
organisation(s) is necessary. The description must be accompanied by all
official legal documents proving/supporting the changes the request is
based on."

The full procedural document is available at:
https://www.ripe.net/publications/docs/ripe-628

So, if an organisation acquires the network infrastructure of another
organisation, for example following a merger or acquisition, we will ask
to see documented legal evidence of this before we will transfer any
resources.

If an organisation holds more than one LIR account, either because it
has opened multiple accounts or as the result of an acquisition as
described above, it may ask us to combine these into a single LIR
account at any time. Where there has been an acquisition, this step of
combining the accounts is mostly done at the same time as the transfer.

If an organisation closes an LIR account after transferring its
resources, it would not be able to request an additional /22 via that
account upon reopening it.

I hope this clarifies matters and answers your questions. If you have
any further questions, please feel free to contact me.

Kind regards,

Laura Cobley
RIPE NCC Customer Services Manager


On 20/05/15 11:06, Daniel Suchy wrote:
> Hello,
> as already discussed in APWG, there're some LIRs, who were opened just
> to obtain additional /22 IPv4 block from last /8 and shortly after
> allocation receipt they're "organizationally merged". Part of this
> problem might be solved by 2015-01 policy proposal. But not all...
> 
> Question, which I would like to ask is procedure, how RIPE NCC checks
> validity of informations provided by merged LIRs (for example, how is
> verified claimed company acquisition and so on). It seems only claims
> from "merged" LIRs are sufficient to allow merge.
> 
> I think, some LIR merges were approved by RIPE NCC even in the fact no
> organizational-merge happens on the market and both organizations remain
> functional and doing their original business without any change. The
> only true reason is reducing expenses (pay one LIR instead of multiple
> ones) after address space is allocated.
> 
> Another question is, what happens, if "already merged/closed" LIR of
> some "branch" is reopened? It will receive additional /22?
> 
> This question is focused to internal RIPE NCC procedures - as community
> policies doesn't regulate that in detail. But if internal procedure of
> RIPE NCC is weak and allows such merges without any resist and (very)
> deep verifications, anyone can easily abuse original spirit of /8
> policy. And I think policy spirit is also important - not every
> situation can be covered in advance by some policy paragraphs - that's
> not really possible. And policy abusers will be always one step ahead.
> 
> I think one of RIPE NCC roles is protection of policy spirit, not only
> policy letter - and allowing such "merges" helps plungers, which're
> opening short-term LIRs for few months purposely.
> 
> With regards,
> Daniel
> 
>