Yes, as mentioned in the CABF in the first link Wayne provided, even for
our other methods, it can be problematic for domain holders to demonstrate
control using particular methods. As Joanna mentioned, .2 can be
problematic in a post-WHOIS world.

I realize that shooting down suggestions doesn't help us build sustainable
solutions, but this was a problem we thought about a lot in the context of
the CT redaction discussions, because the only 'effective' mitigation to
inappropriate redaction was reveal-(and-revoke) - that is, reveal the
redacted name, and possibly revoke the cert if you don't like what was
revealed. Trying to decide how to authorize that request and what the
consequences of that would be occupied a substantial part of our time (...
I promise I didn't hate redaction "just because").

As an example scenario beyond what Wayne pointed out in the
https://cabforum.org/pipermail/public/2018-January/012824.html link,
consider such situations such as All CAs being required to support all
validation methods for revocation. One possible scenario is a lack of
interoperable interpretations of some methods (yet compliant with the
letter) - for example, GlobalSign's validation methods compared to Let's
Encrypt's use of the (draft) ACME validation methods, which comply with the
letter but are different protocols. Another possible scenario is that a CA
only supports a given method for revocation, not issuance, and thus the
robustness of it and the testing of it is far weaker than might be expected
(and detected) for domain validation.

Understandably, we can try to patch those two examples I gave (and there is
useful result in doing so), such as trying to further specify exactly how
domains are validated, or potentially requiring CAs to also support all
such methods for domain validation as well (although determining whether
that means CAs MUST also support DV is a related and natural implication
that follows that sort of policy). However, I was trying to present them to
indicate the sort of holistic challenges we should think about, and why
it's not quite as easy as 'revoke the same way you validated' or 'validate
using any/every possible method'.

So what does that mean for Richard? Well, I agree with Jakob in that he
quoted the appropriate section, and there is a reasonable expectation in
principle for the CA to do due diligence to investigate for possible
revocation. And I think Wayne's directions on revocation do offer a number
of important contributions to that, by providing some degree of flexibility
for CAs to do meaningful investigations (although with some degree of
transparency inevitably being needed when offering CA discretion). And I
think the Root Stores have a role to play in how they communicate that
expectation to CAs, such that domain holders have recourse if the CA is not
taking meaningful steps.

On Fri, Jun 1, 2018 at 5:42 PM, Jeremy Rowley <[email protected]>
wrote:

> Which is yet another reason why removing method 1 and method 5 was a good
> idea.  Do any of the other methods share the same problem? Maybe IP address
> verification right now.
>
>
>
> *From:* Ryan Sleevi <[email protected]>
> *Sent:* Friday, June 1, 2018 2:51 PM
> *To:* Jeremy Rowley <[email protected]>
> *Cc:* Wayne Thayer <[email protected]>; Jakob Bohm <
> [email protected]>; mozilla-dev-security-policy <
> [email protected]>
>
> *Subject:* Re: Namecheap refused to revoke certificate despite domain
> owner changed
>
>
>
> You know I'm strongly supportive of requiring disclosure of validation
> methods, for the many benefits it brings, I'm not sure how that would
> address the concern.
>
>
>
> Consider a certificate validated under .5. Would Richard now need to hire
> a lawyer to say they own their domain name now?
>
>
>
> On Fri, Jun 1, 2018 at 3:38 PM, Jeremy Rowley via dev-security-policy <
> [email protected]> wrote:
>
> This is one of the reasons I think we should require an OID specifying the
> validation method be included in the cert. Then you can require the CA
> support revocation using the same validation process as was used to confirm
> certificate authorization. With each cert logged in CT, everyone in the
> world will know exactly how to revoke an unauthorized or no-longer-wanted
> cert.
>
>
> -----Original Message-----
> From: dev-security-policy <dev-security-policy-bounces+jeremy.rowley=
> [email protected]> On Behalf Of Wayne Thayer via
> dev-security-policy
> Sent: Friday, June 1, 2018 1:02 PM
> To: Jakob Bohm <[email protected]>
> Cc: mozilla-dev-security-policy <mozilla-dev-security-policy@
> lists.mozilla.org>
> Subject: Re: Namecheap refused to revoke certificate despite domain owner
> changed
>
> On Fri, Jun 1, 2018 at 5:06 PM Jakob Bohm via dev-security-policy <
> [email protected]> wrote:
>
> >
> > Please contact the CA again, and inform them that BR 4.9.1.1 #6
> > requires the CA (not some reseller) to revoke the certificate within 24
> hours if:
> >
> >     The CA is made aware of any circumstance indicating that use of a
> >     Fully-Qualified Domain Name or IP address in the Certificate is no
> >     longer legally permitted (e.g. a court or arbitrator has revoked a
> >     Domain Name Registrant’s right to use the Domain Name, a relevant
> >     licensing or services agreement between the Domain Name Registrant
> >     and the Applicant has terminated, or the Domain Name Registrant has
> >     failed to renew the Domain Name);
> >
> > While CAs are not required to discover such situations themselves,
> > they must revoke once made aware of the situation (in this case by you
> > telling them).
> >
> > At least, this is how I read the rules.
> >
> > This issue has come up in several CAB Forum discussions such as [1].
> > In
> practice, I believe that the requirement Jakob quoted is rarely invoked
> because (despite the examples), the language is too vague and narrow. It
> can also be quite difficult for a CA to verify that the revocation request
> is coming from the legitimate domain name registrant [1], making it less
> likely the CA will take action.
>
> I've made a couple of attempts to fix this, resulting in the current
> language proposed for ballot 213 [2]:
>
> The CA obtains evidence that the validation of domain authorization or
> control for any Fully-Qualified Domain Name or IP address in the
> Certificate should not be relied upon.
>
> I'd prefer a more prescriptive requirement that CAs allow anyone to revoke
> by proving that they control the domain name using one of the BR 3.2.2.4
> methods, but this is a problem because most CAs don't support every domain
> validation method and many domains are configured such that some validation
> methods can't be used.
>
> - Wayne
>
> [1] https://cabforum.org/pipermail/public/2018-January/012824.html
> [2] https://cabforum.org/pipermail/public/2018-May/013380.html
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