I think if ARIN wanted to, they could give everyone a year to "substantiate their allocation" and set the policy something like "companies must return for reallocation any overallocations."
The risk of not returning an overallocation, well I'm not sure. ARIN certainly has teeth, and companies should simply be expected to correct these huge overallocations.
Just like the open source community comes together to solve serious problems, if we as a community enforced an ethical standard and some key people stood up raised this as an issue, I'm willing to bet ARIN could replenish a stockpile of IPv4 space.
So the question I'm asking is, since ARIN is empty, clearly they aren't interested in keeping a stockpile of addresses. Why not? I guess the more generous alternative is simply they have failed spectacularly at their stated goal.
ARIN can go over the pool of post 1997 addresses they have allocated, but I think you would find much smaller unallocated blocks.
When the three months are up you can go looking for four more companies, and hire some more lawyers too.