Hello,

I'm investigating an issue on behalf of a customer. Our customer requested a 
multi-year certificate that was issued on March 1st by Comodo.

Here's the certificate:
https://crt.sh/?id=354042595

        Validity
            Not Before: Mar  1 00:00:00 2018 GMT
            Not After : May 29 23:59:59 2021 GMT

The certificate is currently considered invalid at least by Google Chrome.

It's my understanding that Google Chrome uses a >= comparison, which 
effectively means certificates issued on March 1st are already subject to 
Ballot 193.

However, it looks like the interpretation of Comodo of Ballot 193 here is based 
on a > comparison, since the certificate was issued with a 3y validity.

BR 6.3.2 says:

> Subscriber Certificates issued after 1 March 2018 MUST have a Validity Period 
> no greater than 825 days.
> Subscriber Certificates issued after 1 July 2016 but prior to 1 March 2018 
> MUST have a Validity Period no greater than 39 months.

I'd appreciate some hints about whether a certificate issued on March 1st 
should be considered subject to Ballot 193 or not.

Best,
-- Simone
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