> On Aug 15, 2017, at 14:53, identrust--- via dev-security-policy 
> <dev-security-policy@lists.mozilla.org> wrote:
> 
> On Friday, August 11, 2017 at 6:05:29 PM UTC-4, paul.l...@gmail.com wrote:
>> On Friday, August 11, 2017 at 3:43:17 PM UTC-5, iden...@gmail.com wrote:
>>> IdenTrust is fully aware of the situation and has consulted with internal 
>>> and external parties to ensure that our course of action is appropriate and 
>>> commensurate with our business practices and accommodates our customer’s 
>>> needs.
>>> When IdenTrust initially established the ACES SSL profile, it was intended 
>>> to apply only to US government entities.  At that time, the Organization 
>>> was defined as a static value of “U.S. Government” in our profiles.  Later, 
>>> when non-agencies applied, IdenTrust reasoned at that time that this static 
>>> value continued to be acceptable as these entities must identify themselves 
>>> as organizations that act as relying parties, accepting certificates issued 
>>> under the ACES program, and are in some capacity associated with the U.S. 
>>> Government.  We have discussed internally and taken a fresh look at this 
>>> decision.   As a result, IdenTrust has updated the ACES SSL profile to use 
>>> the applicant Organization name in the Subject DN organization field.  This 
>>> change will accommodate all applications for ACES SSL certificates, both 
>>> U.S. agencies and non-agencies.  At the same time, we have modified the 
>>> OCSP validation URL from HTTPS to HTTP.  
>>> It is important to note that all certificates that are impacted by this 
>>> situation have been appropriately vetted by the IdenTrust Registration team 
>>> according to Identity Validation requirements stated in the ACES CP, 
>>> therefore the need to revoke affected certificates immediately is less 
>>> critical.  Our key objective is to revoke all incorrect certificates as 
>>> quickly as possible, while minimizing the impact to our customers and 
>>> avoiding disruption to critical business processes.  As such, IdenTrust is 
>>> working directly with these customers to initiate a replacement for the 
>>> offending certificates.  The replacement process allows the client to use 
>>> an online mechanism to request a new certificate with the correct 
>>> attributes and immediately download the new certificate.  The replacement 
>>> process also automatically revokes the certificate being replaced.  This 
>>> will enable our clients to receive a newly vetted certificate and they will 
>>> not be inconvenienced by a forced revocation, which would likely adversely 
>>> impact their business processes. IdenTrust will ultimately force a 
>>> revocation, in the event that the clients do not initiate a certificate 
>>> replacement in response to our communications.
>>> 
>>> Thank you for the opportunity to represent our position.
>> 
>> Is it Identrust's contention that the revocation rules required under the 
>> requirements they are audited under do not apply to these certificates 
>> because it would inconvenience their customers? This is a clear violation of 
>> the baseline requirements and I'd like some clarity on why Identrust 
>> believes it's permissible to pick and choose what their revocation timelines 
>> will be.
>> 
>> -Paul
> No, IdenTrust is not insinuating that the revocation rules do not apply here. 
>  IdenTrust, upon notification, immediately started reviewing our historical 
> understanding of our ACES SSL program and how it complied with both the ACES 
> CP and CA/B CP. This review involving internal and external resources began 
> in earnest. As previously stipulated, all certificates impacted were 
> appropriately vetted by the IdenTrust Registration team according to Identity 
> Validation requirements stated in the ACES CP.  IdenTrust worked to bridge 
> the gap between historical definitions and CA/B forum compliance while 
> balancing the needs of the community and IdenTrust customers alike. 
> Concurrently, IdenTrust reviewed, implemented and validated programmatic 
> controls prohibiting the population of the "U.S. Government" for ACES 
> non-agency entities. Once our technical fix was verified, our priority 
> objective has been to revoke all non-compliant certificates as quickly as 
> possible, while minimizing the impact to our customers and avoiding 
> disruption to critical business processes.   IdenTrust has been working with 
> the certificate sponsors to initiate a replacement for these identified 
> certificates.  One certificate has been successfully replaced.  For one 
> certificate, the customer has requested an extension until Wednesday 
> (tomorrow) to replace--we have granted this extension, but will revoke if the 
> replacement in not completed by 5 p.m. MT on Wednesday.  For the three 
> certificates where we were not successful in facilitating a replacement, we 
> have completed a revocation.  We will confirm replacement or revocation of 
> the last remaining certificate after 5 p.m. MT tomorrow.

I looked through the CT logs and found 15 more unexpired unrevoked certificates 
that are trusted by NSS and appear to have the same inaccurate organizationName 
of “U.S. Government” for a non-USG entity.

The list is here: https://misissued.com/batch/10/

Can you explain why your review missed these? Are there any more in addition to 
these 15 and previous 5?

Jonathan

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