Baseline Requirements section 7.1 says:

> Effective September 30, 2016, CAs SHALL generate non‐sequential Certificate 
> serial numbers greater than zero (0) containing at least 64 bits of output 
> from a CSPRNG.

There are 1027 unexpired unrevoked certificates known to CT with a notBefore 
date greater than or equal to 2016-09-30 that are trusted by NSS for server 
authentication and have a serial number that has less than 64 bits of entropy.

The full list can be found here:

Some of these were brought up in a previous thread[0], but I though a 
comprehensive picture of this issue would be helpful.

I’ve included a breakdown at the end of this email, and here are a few things 
that stood out to me while researching this:

- The "Cihaz Sertifikası Hizmet Sağlayıcı - Sürüm 4” intermediate appears to 
use randomly generated 48-bit numbers.
- Three intermediates, "TeleSec ServerPass Class 2 CA”, "Go Daddy Secure 
Certificate Authority - G2”, and "Starfield Secure Certificate Authority - G2”, 
(which are not in this list) appear to issue certificates with serial numbers 
that are based on exactly 64 bits of entropy. This means that a small 
percentage of the certificates that they issue have serial numbers that are 
smaller than 8 bytes, requiring additional filtering to avoid false positives. 
It would be helpful if the policy was adjusted to require serial numbers always 
be at least 8 bytes before DER encoding to avoid these false positives.




QuoVadis (560)
    Siemens Issuing CA Internet Server 2016 (560)

D-TRUST (224)
    D-TRUST SSL Class 3 CA 1 2009 (178)
    D-TRUST SSL Class 3 CA 1 EV 2009 (45)
    D-TRUST Root Class 3 CA 2 EV 2009 (1)

DigiCert (85)
    Siemens Issuing CA Class Internet Server 2013 (82)
    InfoCert Web Certification Authority (3)

Izenpe S.A. (62)
    EAEko Herri Administrazioen CA - CA AAPP Vascas (2) (62)

Government of The Netherlands, PKIoverheid (Logius) (55)
    Digidentity Services CA - G2 (55)

Government of Turkey, Kamu Sertifikasyon Merkezi (Kamu SM) (38)
    Cihaz Sertifikası Hizmet Sağlayıcı - Sürüm 4 (38)
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