On Fri, 7 Oct 2016 12:12:58 +0100
Gervase Markham <[email protected]> wrote:

> * WoSign and StartCom are to be legally separated, with the corporate
> structure changed such that Qihoo 360 owns them both individually,
> rather than WoSign owning StartCom.
> 
> * There will be personnel changes:
> 
>  - StartCom___s chairman will be Xiaosheng Tan (Chief Security Officer
>    of Qihoo 360).
>  - StartCom___s CEO will be Inigo Barreira (formerly GM of StartCom
>    Europe).
>  - Richard Wang will be relieved of his duties as CEO of WoSign and
>    other responsibilities. It is not decided who will replace him.
>
> * StartCom will soon provide a plan on how they will separate their
> operations and technology from that of WoSign.
>
> * In the light of these changes, Qihoo 360 request that WoSign and
> StartCom be considered separately.
>
> Mozilla is minded to agree that it is reasonable to at least consider
> the two companies separately

Consider the following hypothetical: Honest Achmed's Used Cars and
Certificates operates two roots, Honest Achmed Root A and Honest Achmed
Root B.  The two roots share much of the same infrastructure, and over
the same period of time, both roots have serious incidents, including
Honest Achmed himself approving the backdating of SHA-1 certificates
under both roots.

After the incidents come to light, Honest Achmed's majority owner,
Uncle Mehmet, fires Honest Achmed and places Root A and Root B under
the control of two separate companies.  He asks that Mozilla consider
the fate of Root A and Root B separately.

That seems like a very unreasonable request to me - a mismanaged CA
shouldn't be able to save some of their roots by spinning them off into
a separate company after they're caught.  How is WoSign/StartCom
different?  It doesn't matter that at one point in the past WoSign and
StartCom were separate companies.  During the time that the incidents
occurred, StartCom and WoSign were for all intents and purposes the
same company, one wholly owned by the other, both managed by the same
disgraced CEO, and sharing significant infrastructure.  They should
therefore be treated as the same company when responding to these
incidents.

Any restructuring and personnel changes at this point could influence
Mozilla's future consideration of StartCom and WoSign (e.g. during root
inclusion requests) but it cannot change the past and therefore should
not alter how Mozilla responds to what happened in the past.

Regards,
Andrew
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