On Sun, Dec 16, 2018 at 11:49 PM please please <[email protected]> wrote:
> I just noticed that Comodo CA has finally posted its incident report in > https://bugzilla.mozilla.org/show_bug.cgi?id=1492006 > > Comments: > - The report suggests that no BR violation occurred because I was not the > Subscriber to fulfill the conditions in bullet point 1 of BR 4.9.1.1. > However, I believe I fulfilled the conditions for triggering the 24 hours > revocation anyway because of bullet point 6 of the same BR, which states "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 relevant licensing or services agreement between > the Domain Name Registrant and the Applicant has terminated [...])", as I > explicitly stated in my initial revocation request email that Cloudflare > was no longer authorized to represent my domain but still controlled the > private keys. > Sectigo's (formerly Comodo's) response does seem to both admit the violation and downplay it. Shortly after the violation the BRs were changed to allow 5 days for most revocations, and that may be the motivation for calling out that the Subscriber didn't request revocation. However, I believe this case still falls under the 24-hour rule due to 4.9.1.1(4): 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. - Comodo CA claims that my request was "potentially ambiguous", but did not > explain in what regard, nor did they ever asked me for clarifications. I > can only assume as of now that the issue was to get an exhaustive list of > certificates as I ran into the same problem and could not do so efficiently > myself, but assumed Comodo CA would have had the means necessary to extract > them easily from their own data based on my request. > I've requested more information in the bug. This may be a case of Sectigo falling back on the interpretation that the revocation clock doesn't start until the certificates have been identified. However, Sectigo also accepts responsibility by stating "The urgency of the revocation request was not adequately communicated as the request was passed along." - I'm concerned that the incident report was posted more than 2 months past > Mozilla's soft deadline to do so, especially when considering that the > incident was also about being late to take necessary action for a deadline. > > Yes, this is a concern. When a CA exhibits a pattern of slow responses, it is taken into consideration when Mozilla is making decisions about the CA, such as whether to include new roots. Let me know if you need additional information from me to complete your > assessment of the incident. > > Guillaume Fortin-Debigaré > ------------------------------ > *From:* please please <[email protected]> > *Sent:* October 11, 2018 19:19 > *To:* Wayne Thayer > *Cc:* MDSP > *Subject:* Re: Violation report - Comodo CA certificates revocation delays > > I was under the impression that CAs were allowed to remove CRL entries and > OCSP support for expired certificates for some reason. Good to know! > > On a slightly-unrelated note, you might also want to poke Comodo CA about > https://bugzilla.mozilla.org/show_bug.cgi?id=1461391 > > Thanks again! > > Guillaume Fortin-Debigaré > ------------------------------ > *From:* Wayne Thayer <[email protected]> > *Sent:* October 11, 2018 13:53 > *To:* [email protected] > *Cc:* MDSP > *Subject:* Re: Violation report - Comodo CA certificates revocation delays > > I just poked Comodo in the bug - > https://bugzilla.mozilla.org/show_bug.cgi?id=1492006 > > CT Logs are designed such that certificates cannot be removed from them. > The evidence will not disappear once the certificates expire. > > On Wed, Oct 10, 2018 at 5:26 PM please please <[email protected]> > wrote: > > Any update behind the scenes about this issue? I've noticed that the soft > limit to fill an Incident Report expired more than a week ago, and I'm > starting to be a bit worried that some of the evidence in the CT logs might > disappear if the investigation is not completed before December 6th, the > earliest expiration date among the affected certificates. > > Guillaume Fortin-Debigaré > ------------------------------ > *From:* please please <[email protected]> > *Sent:* September 17, 2018 23:39 > *To:* Wayne Thayer > *Cc:* MDSP > *Subject:* Re: Violation report - Comodo CA certificates revocation delays > > Good to know, and thank you very much for following up on this! > > Small update by the way: I finally received a reply from Comodo CA > confirming their 2nd wave of revocations a few hours ago, on September 17 > at 16:55 UTC to be exact. Strangely, it was in response to an email where I > informed them that I had already noticed they fully completed my revocation > request. I don't think it's a relevant detail but I wanted to mention it to > avoid any potential confusion. > > Guillaume Fortin-Debigaré > > ------------------------------ > *From:* Wayne Thayer <[email protected]> > *Sent:* September 17, 2018 20:09 > *To:* [email protected] > *Cc:* MDSP > *Subject:* Re: Violation report - Comodo CA certificates revocation delays > > I have created a bug and requested a response from Comodo: > https://bugzilla.mozilla.org/show_bug.cgi?id=1492006 > > As noted, there are no specific requirements regarding how CAs validate > revocation requests in the BRs. Every CA may do this however they choose, > so I don't believe there is any action required in regard to DigiCert's > response to their problem report. > > - Wayne > > On Sun, Sep 16, 2018 at 8:30 PM please please via dev-security-policy < > [email protected]> wrote: > > Hello, I am the domain owner of debigare.com. I would like to make you > aware that Comodo CA took more than 5 days to revoke certificates they had > signed for my domain and subdomains after requesting them to do through > their sslabuse email address, past the 24 hours maximum mentioned in the > Baseline Requirements as stipulated in section 4.9.1.1. > > For context, I was previously using Cloudflare's Universal SSL feature, > but disabling it did not revoke the old certificates that had not yet > expired, but simply removed them from its system, and some of the > certificates were still valid for more than 6 months. > > I first attempted to contact Cloudflare's support to ask them to revoke > the certificates themselves on September 6 at 7:43 UTC. This only led to > irrelevant responses and confused customer support agents that had no idea > what I was talking about, and this appeared to go nowhere. I eventually got > a response from them on September 11 at 5:53 UTC that they would request > CAs to perform the revocation, but that was after I did so myself, and I > never got a status report back afterwards. > > There were two CAs affected by this issue. The vast majority of > certificates were signed by Comodo CA, and the rest by DigiCert. I did not > run into any issues with DigiCert (they in fact proactively checked with > Cloudflare my claim and revoked the certificates before I even had the > chance to attempt their domain ownership challenge), but Comodo CA was > another story entirely. > > My first request to Comodo CA to revoke the certificates for debigare.com > and all of its subdomains was on September 8 at 4:37 UTC. I did not get a > reply until September 9 at 15:53 UTC stating that the certificates have > been revoked. Not only was this past the 24 hours requirement, but it was > also false, as only the most recent certificates had been revoked, not all > of them. I mentioned to them their mistake on September 10 at 5:55 UTC with > a full list of affected certificates just in case my initial request was > unclear to them, and never got a reply back. I did, however, notice that > the certificates eventually got revoked on September 13 at 16:04 UTC > according to their Certificate Transparency logs, a fact that I only > discovered on September 15. Assuming the log is correct, that would be a > delay of more than 3 days after notifying them of the incomplete > revocation, more than 5 days after my initial request to them, and more > than a week until I finally noticed the problem was fixed. It's also worth > noting that throughout this entire series of events, Comodo CA never > requested proof of domain ownership beyond the evidence I initially > provided, so that cannot explain the delays. > > One detail that I'm not sure about is why my initial evidence for domain > ownership was apparently sufficient for Comodo CA but not for DigiCert. On > this regard, the only evidence I provided to both of them was that the > email address I used to contact them matched the contact information on my > website. (My emails were protected with SPF, DKIM and DMARC for > authenticity.) For some reason, DigiCert believed that this evidence did > not met the Baseline Requirements for my request, a claim that I am > currently unable to verify as I cannot find anything of the sort in them. > > You can read the full story on my blog, which I hope will be sufficient to > prove my identity: > https://www.debigare.com/4-unexpected-issues-i-encountered-upon-switching-web-hosts/ > > I can also provide a full copy of the email exchange I had with Comodo CA > as evidence on request. > > Guillaume Fortin-Debigaré > _______________________________________________ > dev-security-policy mailing list > [email protected] > https://lists.mozilla.org/listinfo/dev-security-policy > > _______________________________________________ dev-security-policy mailing list [email protected] https://lists.mozilla.org/listinfo/dev-security-policy
