At Rich's request, here are the technical parts.  I assume that the
editors will be trawling through the entirety of the original mail
(for which I apologize).

These are just the headline items, I pulled two forward because I
think they are more important.  The others are small beans.  Of course
I'm happy to be wrong about any of these.

S6.3.2

   [...] and MUST reflect [the?] value of the
   "external-account-binding" field in the resulting account object

Is this a direct copy of the MAC that was provided?  Do you realize
that this enables a user with access to any account that was created
with a binding to replay the binding in new accounts without actually
having the MAC key?  Would it be acceptable to just reflect that the
binding exists?  (Potentially bad idea: just include the key id; if
the CA wants, that key identifier could be a URL to the external
account details page and do double-duty.)

Note that this would be a violation of the stated security goal of not
having integrity compromised by a TLS MitM or CDN.  It doesn't
necessarily permit misissuance unless the binding to the account
carries authorizations across, or things like that.

S6.3.4

   It is up to server policy
   how long to retain data related to that account, whether to revoke
   certificates issued by that account, and whether to send email to
   that account's contacts.

This is terrible.  If I wish to decommission an account key, then I
can't because I might find that my certificates are all suddenly
revoked.  Think about a large organization that has a pool of
authorized accounts used for managing certificates.  If one of those
needs to fall out of the pool (the machine hosting the key is being
scrapped or rebuilt, for instance), then you don't want to have all
the certificates that it issued disappearing suddenly.

If there are good reasons to revoke certificates, then be definite
about it and say that they go away, at least then people can plan
around the problem.

S5.2

   Servers MUST NOT respond to GET
   requests for resources that might be considered sensitive.

Since this is a requirement, it might pay to do a little due diligence
on what might be sensitive.  I'm not sure that all implementers will
have the same view (or same motivations) when it comes to this.

S5.7

In a couple of places, a specific error URN is mandated (with MUST),
but this section only uses SHOULD for the error description.

   Authorization and challenge objects can also contain error
   information to indicate why the server was unable to validate
   authorization.

Where and how would this appear?  This needs more definition (I
looked, but I didn't find anything further down).

S6.1.4

   [[ Open issue: More flexible scoping? ]]

Red flag.  In my view, the simple approach is fine.  New authorization
resources are cheap.  They can even be cloned easily, even allowing
one challenge to fulfill multiple.

S6.4.1

   The server can also provide the client with direct access to an SCT
   for a certificate using a Link relation header field with relation
   "ct-sct".

Where is this link relation type registered?  It isn't in either the
IANA considerations section or in the registry:
http://www.iana.org/assignments/link-relations/link-relations.xhtml

The same goes for the other link relation types that are used in the
example.  I see neither "revoke" nor "directory" being registered.
BTW, "index" would probably do well instead of "directory", "revoke"
seems specific enough to this usage - like "ct-sct" that using a URI
for the relation type would probably be better than registering a link
relation.

S6.5.1

   In responding to poll requests while
   the validation is still in progress, the server MUST return a 202
   (Accepted) response

The 202 is an odd choice here.  The resource exists and has content,
so 200 works perfectly well for this purpose.

S6.6

   The server MAY disallow a subset of reasonCodes from
      being used by the user.

Does a server ignore the reasonCode, or does it reject the request
when an impermissible code is chosen by the client?

S9.2

   For identifiers
   where the server already has some public key associated with the
   domain this attack can be prevented by requiring the client to prove
   control of the corresponding private key.

This doesn't seem right.  I believe that the model permits multiple
accounts to act for a single domain.  Not doing so would represent a
pretty big operational burden.  What public key does this then refer
to?  Or is this promise not valid?

S9.3

You should also recommend rate limits on account creation, or your
other mitigations might be weakened.

S9.4

Does an ACME server send Referer[sic]?  What should it set it to?

S10.2

   A CA that accepts TLS-based proof of domain control should attempt to
   check whether a domain is hosted on a domain with a default virtual
   host before allowing an authorization request for this host to use a
   TLS-based challenge.  A default virtual host can be detected by
   initiating TLS connections to the host with random SNI values within
   the namespace used for the TLS-based challenge (the "acme.invalid"
   namespace for "tls-sni-02").

This doesn't seem right.  If the default vhost is an attacker, then
they can generate the answers the server expects.  Based on this text,
I don't actually know what the right answer might be, is it a TLS
unrecognized_name alert?

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