On Wednesday, September 26, 2018 at 6:12:22 PM UTC-7, Ryan Sleevi wrote:
> Thanks for raising this, Ian.
> 
> The question and concern about QIIS is extremely reasonable. As discussed
> in past CA/Browser Forum activities, some CAs have extended the definition
> to treat Google Maps as a QIIS (it is not), as well as third-party WHOIS
> services (they’re not; that’s using a DTP).
> 
> In the discussions, I proposed a comprehensive set of reforms that would
> wholly remedy this issue. Given that the objective of OV and EV
> certificates is nominally to establish a legal identity, and the legal
> identity is derived from State power of recognition, I proposed that only
> QGIS be recognized for such information. This wholly resolves differences
> in interpretation on suitable QIIS.
> 
> However, to ensure there do not also emerge conflicting understandings of
> appropriate QGIS - and in particular, since the BRs and EVGs recognize a
> variety of QGIS’s with variable levels of assurance relative to the
> information included - I further suggested that the determination of a QGIS
> for a jurisdictional boundary should be maintained as a normative whitelist
> that can be interoperably used and assessed against. If a given
> jurisdiction is not included within that whitelist, or the QGIS is not on
> it, it cannot be used. Additions to that whitelist can be maintained by the
> Forum, based on an evaluation of the suitability of that QGIS for purpose,
> and a consensus for adoption.
> 
> This would significantly reduce the risk, while also further reducing
> ambiguities that have arisen from some CAs attempting to argue that
> non-employees of the CA or QGIS, but which act as intermediaries on behalf
> of the CA to the QGIS, are not functionally and formally DTPs and this
> subject to the assessment requirements of DTPs. This ambiguity is being
> exploited in ways that can allow a CA to nominally say it checked a QGIS,
> but is relying on the word of a third-party, and with no assurance of the
> system security of that third party.
> 
> Do you think such a proposal would wholly address your concern?

I think I'll always agree with removing intermediaries from the validation 
process. Outside of practical concerns, a whitelist of QGIS entities sounds 
like a good idea.

I would wonder what the replacement for D&B is in the United States. You can 
normally get an address for a company from a QGIS but not (from the states I've 
seen) a phone number for callback verification.
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