Kathleen,

I believe that certificate authorities should be content-neutral.  They
should not be required to assess "misuse" or "fraud," nor be required
to revoke certificates except upon request of the owner of a domain
listed in the certificate.

Requiring CAs to police website content is incompatible with Mozilla's
goal of deprecating non-secure HTTP.  Requiring HTTPS for all sites is
only attainable if all sites can easily obtain certificates, and
content policing by CAs undermines that.  As the operator of an
automated certificate reseller, I have witnessed countless cases of
certificate authorities flagging certificate requests as "High Risk"
due to the DNS name being supposedly similar to a popular brand name.
Without exception, every time has been a false positive.  The best
outcome is a multi-hour delay as a human reviews the website, and the
worst outcome is an outright rejection of the request.  Either way, it
creates uncertainty: you don't know if or when you can get a
certificate, which makes it hard to automate certificate deployment,
which makes it hard to deploy HTTPS.  Given that CAs have only the
DNS name on which to base their decision, a high false positive rate
seems inevitable.

Requiring CAs to revoke certificates based on website content creates
another way for websites to be taken offline.  What recourse does a
site operator have when their certificate is erroneously revoked by a
CA?  How can websites that host user-uploaded content operate? These
are difficult questions which will need adequate answers if HTTPS is to
become mandatory for all websites.  It would be much better if CAs
weren't required to police content and instead focused solely on what
certificates are meant to do: certify that a public key belongs to a
particular entity.

Protecting users from malicious content should be left to the
software processing the content (e.g. Firefox), which can do a better
job than a CA ever could.  Firefox already uses Google Safe Browsing to
protect users from phishing and malware.  It works for content
delivered over both HTTPS and HTTP, doesn't suffer from the multi-day
delay inherent with certificate revocation, and can operate on a
per-file level, using the URL or the hash of the file.  Thus, a known
malware file can be blocked even when it appears on a brand new domain,
and if only a single file on a domain is malicious, only that file is
blocked instead of the entire site, which would cause collateral damage
in the case of a site like GitHub which serves user-uploaded content.

Regards,
Andrew
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