This discussion has covered a lot of ground. Here are my comments:

1. Nazwa is not independently audited, nor are they a member of the Mozilla
root program. I am also unable to locate any information that makes Nazwa
an Affiliate of Certum. I believe they are simply a Certum reseller. In
this instance CAA processing is required. Certum states that the CAA record
was validated, leaving me to conclude that Nazwa changed the CAA record
without the domain name registrant's permission.

2. Nazwa is generating the key pair. We recently discussed Trustico [1] and
concluded that - for resellers - this practice is discouraged but not
forbidden. I would encourage Certum to review the Trustico incident and
consider the implications of Nazwa's practices.

3. While I agree that "misissued" as currently used is a very broad term, I
think this is okay. It has meaning in context, and there's no handy word to
replace "misissued" when referring to certificates "issued in violation of
a policy".

4. I agree with Ryan that attempting to categorize misissuance is harmful
to the community. As proposed, it makes non-compliance for policy issues -
in fact, for anything the CA wants to argue isn't a security risk -
tolerable. This is a very slippery slope that ends with MUST == SHOULD.

5. I'm still working on a CAB Forum ballot that relaxes revocation
requirements to 5 days in many cases [2]. Now that governance reform is
mostly complete, I plan to move forward with this.

6. For the most part, I view the revocation of misissued certificates as a
CA's decision to either follow or willingly violate the BRs. It may be
tolerated when a CA chooses not to revoke (or delay revocation), but that
still reduces my confidence in the CA. The only case in which I think
Mozilla should consider relieving a CA of their obligation to revoke under
the BRs is when doing so would have a substantial negative impact on
Mozilla's users.

7. While it would be nice have a bright line for distrust decisions, I
don't know how to achieve that given the number of factors involved. The
manner in which a CA responds to an incident, past history, and the
specific nature of the incident are among the subjective elements that
affect those decisions.

- Wayne

[1]
https://groups.google.com/d/msg/mozilla.dev.security.policy/Xio6mrdxp2M/m38TJkblAgAJ
[2] https://github.com/cabforum/documents/compare/master...wthayer:patch-1

On Tue, Jul 31, 2018 at 8:38 AM Jeremy Rowley via dev-security-policy <
[email protected]> wrote:

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