We believe our proposed dates reflect an aggressive but achievable period of 
time to implement the SubCA proposal and allow impacted organizations the time 
needed to replace, test and operationalize replacement certificates in their 
infrastructure to mitigate interoperability and compatibility risk associated 
with this premature replacement of certificates, which is consistent with the 
intent of the SubCA proposal. Our proposed dates are informed by the RFP 
responses and follow-up discussions we have had with our prospective Managed CA 

From: Eric Mill [mailto:e...@konklone.com]
Sent: Wednesday, July 19, 2017 3:43 PM
To: Steve Medin <steve_me...@symantec.com>
Cc: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: [EXT] Symantec Update on SubCA Proposal

On Wed, Jul 19, 2017 at 11:31 AM, Steve Medin via dev-security-policy 

   > -----Original Message-----
   > From: dev-security-policy 
 On Behalf Of
   > Jakob Bohm via dev-security-policy
   > Sent: Tuesday, July 18, 2017 4:39 PM
   > To: 
   > Subject: Re: [EXT] Symantec Update on SubCA Proposal
   > Just for clarity:
   > (Note: Using ISO date format instead of ambiguous local date format)
   > How many Symantec certs issued prior to 2015-06-01 expire after 2018-
   > 06-01, and how does that mesh with the alternative date proposed
   > below:
   > On 18/07/2017 21:37, Steve Medin wrote:
   > > Correction: Summary item #3 should read:
   > >
   > > 3. May 1, 2018
   > >     a. Single date of distrust of certificates issued prior to 6/1/2016.
   > (changed from August 31,2017 for certificates issued prior to 6/1/2015 and
   > from January 18, 2018 for certificates issued prior to 6/1/2016).
   > >

   Over 34,000 certificates were issued prior to 2015-06-01 and expire after 
2018-06-01. This is in addition to almost 200,000 certificates that would also 
need to be replaced under the current SubCA proposal assuming a May 1, 2018 
distrust date. We believe that nine months (from August 1, 2017 to May 1, 2018) 
is aggressive but achievable for this transition — a period minimally necessary 
to allow for site operators to plan and execute an orderly transition and to 
reduce the potential risk of widespread ecosystem disruption. Nevertheless, we 
urge the community to consider moving the proposed May 1, 2018 distrust date 
out even further to February 1, 2019 in order to minimize the risk of end user 
disruption by ensuring that website operators have a reasonable timeframe to 
plan and deploy replacement certificates.

   That's pretty close to saying that nothing should happen, since almost all 
the certificates will have expired by then. That certainly is the least 
disruptive, but it seems contrary to the intent of the proposal.

   -- Eric

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