Steve, Thank you for responding relatively promptly (at least as compared to previous Symantec responses) to Devon's questions.
However, these responses seem to imply that a side effect of the sale *is* to skirt the remediation requirements imposed by Google and Mozilla. In particular, the agreed upon plan requires issuance (and information verification) by a managed SubCA that does *not* involve Symantec processes, equipment, personnel, etc., until trust in those equipment, people, and processes is established. if Digicert were *not* acquiring any of the equipment/personnel/processes from Symantec, only the customers, this would seem to meet the spirit and letter of the Symantec remediation plan. However, the publicly announced details of the acquisition [Devon ref. 2] explicitly state that equipment and personnel will be transferred from Symantec to Digicert. Combined with the answers below, this means that as soon as the deal closes and this transfer occurs, there is no barrier to the formerly-Symantec-but-now-Digicert equipment and personnel from immediately assisting in the issuance of new certificates (presumably under the Digicert roots). This seems to go against the spirit (and possibly letter) of the remediation plan, which was designed to prevent the bad practices within the existing Symantec CA organization from being involved in further issuances until a level of trust could be demonstrated. Perhaps you or Digicert could clarify why you believe the above to not be the case. Thank you. On Friday, August 11, 2017 at 8:32:33 PM UTC-4, Steve Medin wrote: > > -----Original Message----- > > From: dev-security-policy [mailto:dev-security-policy- > > bounces+steve_medin=symantec....@lists.mozilla.org] On Behalf Of > > Devon O'Brien via dev-security-policy > > Sent: Wednesday, August 09, 2017 12:24 PM > > To: mozilla-dev-security-pol...@lists.mozilla.org > > Subject: [EXT] Re: Symantec Update on SubCA Proposal > > > > Hello m.d.s.p., > > > > I'd just like to give the community a heads up that Chrome’s plan remains to > > put up a blog post echoing our recent announcement on blink-dev [1], but > > in the meantime, we are reviewing the facts related to Symantec’s sale of > > their PKI business to DigiCert [2]. > > > > Recently, it has come to our attention that Symantec may have selected > > DigiCert from the RFP process to become a Managed CA Partner. As defined > > in Google’s first Managed CA proposal [3], then supported by Symantec’s > > commitment to “[cover] all aspects of the SubCA proposal” [4], and finally > > reiterated in Google’s final proposal [1], the requirement has always been > > that the Managed Partner Infrastructure be operated by an independent > > and non-affiliated CA while Symantec worked to rebuild the web > > community's confidence. > > > > Based on this information, we have a series of questions that we’d like > > Symantec to address for public discussion: > > > > 1. Just to confirm, Did Symantec select DigiCert to be Managed CA Partner > > under the RFP process? If so, in light of DigiCert’s acquisition of > > Symantec’s > > PKI business and Symantec’s substantial equity investment in DigiCert, can > > you explain how you believe selecting DigiCert as the Managed CA Partner > > meets the stated requirement of being an independent and non-affiliated > > organization? > > > > Before we initiated our SubCA RFP process in May, Google provided Symantec > with a list of Certificate Authorities, including DigiCert, which met the > eligibility requirements of a Managed CA under the SubCA proposal. Symantec > conducted a thorough SubCA RFP process and believes DigiCert can credibly > meet browser requirements and timelines. > > Symantec decided it was in the best interests of all of its stakeholders to > sell its Website Security and related PKI solutions to DigiCert. To ensure > business continuity for customers, Symantec entered into a SubCA arrangement > with DigiCert simultaneous with entry into the definitive acquisition > agreement to account for the possibility that the acquisition may not close > by December 1, 2017. > > Regardless of whether the acquisition closes before December 1, 2017 or not, > there is never a circumstance under which DigiCert will be an 'affiliate' of > Symantec with respect to acting as Symantec's Managed CA under the SubCA > proposal. Symantec currently has no ownership interest in or ability > (contractual or otherwise) to control the operations of DigiCert, nor does > either party otherwise constitute an 'affiliate' of the other, as such term > is defined in the CA-Browser Forum Baseline Requirements (v 1.4.9). > > At the closing of the acquisition, Symantec is being paid in both cash and > stock, with the latter comprising a 30% ownership interest in the common > equity of DigiCert, which allows for Symantec stockholders to benefit from > the potential value created by the DigiCert business after the closing. This > minority ownership position, which shall not be received by Symantec until > the closing of the acquisition, represents a financial investment in > DigiCert. This financial investment does not give Symantec control over > DigiCert's CA technology, operations or business, and therefore we believe > that it satisfies the spirit of the non-affiliate status that the browser > community was seeking to achieve through the SubCA proposal. > > It is Symantec's understanding that all certificates issued by DigiCert on or > after December 1, 2017 and the closing of the acquisition will chain to > DigiCert's existing public roots. If the acquisition closes before December > 1, 2017, then no certificates will ever be issued by DigiCert as a Managed CA > of Symantec because DigiCert will not be issuing certificates under a new ICA > that chains to a new Symantec PKI. Rather, in this instance, certificates > will either (i) be issued off of Symantec’s existing PKI, which is permitted > under the SubCA proposal until November 30, 2017, or (ii) be issued off of > DigiCert’s existing PKI. The actual timing of the acquisition closing > relative to the parties’ operational integration planning schedule will > determine whether certificates are issued under both scenarios or just the > latter. > > If the acquisition does not close before December 1, 2017, then DigiCert has > agreed to serve as Symantec's Managed CA partner as of December 1, 2017, but > will not be an 'affiliate' during this pre-closing period for the reasons > explained above. > > > 2. Were any additional CAs selected to be a Managed CA Partner from the > > list of trusted CAs that Symantec “felt best met the browser requirements”? > > > > There were no additional CAs selected to be a Managed CA partner. Symantec > conducted a thorough SubCA RFP process and believes DigiCert can credibly > meet browser requirements and timelines. > > Although we believe the DigiCert transaction achieves the goals of Google and > Mozilla and the extended browser community (transition away from Symantec's > existing PKI and issuance platform to one that is accepted by browsers) as > well as our own goals (minimize customer disruption), there are important > differences between this sale transaction and the SubCA proposal. Under the > SubCA proposal, Symantec SSL/TLS certificates would be issued through one or > more independently operated third-party CAs – under an ICA that chains to a > new private PKI issued by Symantec and which is cross-signed by Symantec's > existing PKI – until Symantec developed and deployed a modernized PKI > platform that is accepted into trust stores. After the closing of the > DigiCert acquisition, our customers will be issued SSL/TLS certificates from > DigiCert’s existing PKI and platform, which is currently available and > publicly trusted by all browsers. > > Symantec decided it was in the best interests of all of its stakeholders to > sell its Website Security and related PKI solutions to DigiCert because this > transaction accelerates the transition for our customers to an existing PKI > platform at DigiCert that meets all industry standards and browser > requirements, ensuring continuity for our customers and providing a > foundation for continued innovation. _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org https://lists.mozilla.org/listinfo/dev-security-policy
