They were until Feb 2013 :)

Sure - let's discuss these issues at the CAB Forum. Based on the spreadsheet, 
I'm pretty sure lots of CAs would like to re-address the elimination of all 
SANs except iPAddress and dNSANames.  

-----Original Message-----
From: Rob Stradling [] 
Sent: Tuesday, November 17, 2015 2:12 PM
To: Jeremy Rowley
Cc: Richard Wang;; Peter Bowen; 
Peter Gutmann
Subject: Re: [FORGED] Name issues in public certificates

On 17/11/15 18:27, Jeremy Rowley wrote:
> Encoding an IP Address in a dNSName is not permitted by the BRs.  This is 
> what Peter's "_ipv4_not_allowed_here" rule refers to, IIUC.
> [JR] I suppose that is true under but how would you get the 
> browsers to work back then? Chrome and IE did not process ipAddress properly.

Jeremy, I don't recall any clause in the BRs that permits CAs to ignore 
requirements that they or their customers don't like.

They are not Baseline Suggestions! ;-)

If (whilst the BRs have been in force) there's been a perceived need to encode 
IP addresses in dNSName fields, then don't you think that the correct thing to 
do would've been to take the matter to CABForum and seek to update the BRs so 
that this practice is permitted?

> Jeremy
>> Regards,
>> Richard
>> -----Original Message-----
>> From: dev-security-policy
>> [
>> o
>> rg] On Behalf Of Rob Stradling
>> Sent: Tuesday, November 17, 2015 9:32 PM
>> To: Peter Gutmann <>; Peter Bowen 
>> <>;
>> Subject: Re: [FORGED] Name issues in public certificates
>> On 17/11/15 08:25, Peter Gutmann wrote:
>>> Peter Bowen <> writes:
>>>> There are a couple of rules that may create false positives, so 
>>>> please don't assume every certificate on the sheet is problematic.
>>> That's still pretty scary, nearly 50,000 names from a who's-who of 
>>> commercial CAs.  Yet more evidence that, like the output from the 
>>> EFF SSL Observatory, we need independent assessment of browser PKI 
>>> rather than self-certification ("we define ourselves to be in full 
>>> compliance with everything we need to be compliant with, as far as we can 
>>> tell").
>>> Peter.
>> Peter (G),
>> I fully agree that independent assessment is useful, but independent 
>> assessments need to be assessed too (preferably before the press 
>> start quoting soundbites! :-) )
>> Peter (B),
>> Thanks for doing this report.  There are definitely some interesting 
>> findings.
>> However, I would like to discuss several classes of (what I think 
>> are) false positives that cover a significant number of the "anomalies" 
>> you've found:
>>      - RFC5280 sections 7.2 and 7.3 do indeed talk about the need for 
>> dNSNames, domainComponents, etc, to only contain ASCII data.  
>> However, your report also flags Subject CNs with non-ASCII data - 
>> AFAICT, this is permitted by both
>> RFC5280 and the BRs.  It is common practice to put the "xn--" ASCII 
>> string in a dNSName and the UTF-8 string in the Subject CN.
>>      - You wanted to check that "public CAs were following the 
>> CA/Browser Forum baseline requirements" when issuing certs.  However, 
>> some of the certs in your report were issued before any of the 
>> browsers / audit regimes demanded that public CAs be compliant with the BRs.
>> Furthermore, some of the certs in your report were issued before the 
>> BRs even existed.
>>      - You wanted to check "server auth certificates issued by public CAs".
>> However, I see some Code Signing Certificates in your report.
>> I'm pretty optimistic that all of the "anomalies" issued by Comodo's 
>> CA system (except for the 8 mentioned in our recent incident report) 
>> will be found to fall into these categories, although I haven't done 
>> an exhaustive analysis yet.  If there are any other "anomalies", 
>> they're a bit lost in the noise at present!

Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online
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