Look forward to seeing and discussing once the full scope of the request is
shared.

On Wed, Dec 19, 2018 at 12:21 PM Jeremy Rowley <[email protected]>
wrote:

> We will post the full list of exceptions today.
>
>
>
> One of the big factors should be the risk to the industry/community if the
> certificates aren’t revoked. Perhaps we can identify what the risk to the
> community is in revocation delays first? There’s no need to know the exact
> certs to talk about what the risk associated with underscore characters is.
> Could you please explain the risk to the community in a revocation delay as
> the “unreasonable” argument isn’t really supported without that
> understanding.
>
>
>
> *From:* Ryan Sleevi <[email protected]>
> *Sent:* Wednesday, December 19, 2018 7:17 AM
> *To:* Jeremy Rowley <[email protected]>
> *Cc:* [email protected]; mozilla-dev-security-policy <
> [email protected]>
> *Subject:* Re: Underscore characters
>
>
>
> While I appreciate you sharing what you have, as I tried to capture in my
> previous message, I don't believe there can be any discussion or
> consideration in earnest without the full and final information. I don't
> think it's reasonable to drip in information piece meal, given the impact
> and affect that can have - whether incomplete information for the issue or
> whether additional customers being added.
>
>
>
> You're making a huge request of the community, arguably one that
> borderlines unreasonable given the set of issues had in the past. I do want
> to help you achieve your goal of understanding what that would look like,
> but that's only possible with full and complete information. You mentioned
> it's roughly 15 companies. If you had ten committed, but were waiting on
> the remaining five to give the OK, I think it would be irresponsible to
> hold up having that conversation until you get the OK. Quite simply, if you
> don't get the OK from those five companies, then we shouldn't even be
> discussing them. Ultimately, the ball is in your court as to how you want
> to address this with your customers, but I think that delaying the
> conversation in order to make sure "stragglers" are included is probably
> not the wisest for your customers that have their stuff together.
>
>
>
> As such, I don't think the conversation can begin without that
> (hypothetical) incident report, and I look forward to you deciding what
> that scope will be in order to share and commit to it.
>
>
>
> On Tue, Dec 18, 2018 at 9:51 PM Jeremy Rowley <[email protected]>
> wrote:
>
> Yeah – I’ll be providing an accurate incident report (working on gathering
> all the information). The incident report assumes we don’t revoke of
> course. Revocation is still on the table. However, I wanted to start the
> conversation with everything I know so far:
>
> 1) ~2200 certs
>
> 2) Roughly 15 companies
> 3) Only one has publicly chimed in so far on the Mozilla thread (still
> hoping more will…)
>
> 4) Revocation of all certs will occur by May 1, 2019, depending on how the
> discussion here goes.
> 5) The common thread is that the Jan 15th deadline falls in the blackout
> window of most orgs. They generally come off it between Jan 15-Feb 15. They
> can’t replace the cert or change the domain so the 30 day cert option
> doesn’t help.
>
> 6) We provided notice as soon as the ballot passed. We blocked issuance
> prior to that date, but we’d hoped that the certs could remain valid until
> expiration. We had trouble with our BI providing the information so some
> notices went out later than I’d hoped. I’ll find the exact date on when all
> notices were complete.
>
>
>
> Ballot 202 failed. I’m not sure how it’s relevant other than to indicate
> there was definite disagreement about whether underscores were permitted or
> not. As previously mentioned, I didn’t consider underscore characters
> prohibited until the ballot was proposed eliminating them in Oct. I know
> the general Mozilla population disagrees but, right or wrong, that’s the
> root cause of it all. I can explain my reasoning again here, but I doubt it
> materially alters the conversation and outcome.
>
>
>
> *From:* Ryan Sleevi <[email protected]>
> *Sent:* Tuesday, December 18, 2018 7:35 PM
> *To:* Jeremy Rowley <[email protected]>
> *Cc:* mozilla-dev-security-policy <
> [email protected]>
> *Subject:* Re: Underscore characters
>
>
>
> Jeremy,
>
>
>
> It seems like any answer for what it "might" look like if a CA violated
> the BRs in a particular way is going to be predicated on what the incident
> report says. In the case of a hypothetical like this, it seems like the
> hypothetical incident report would discuss what is planned or proposed, and
> should a CA go forward with such an intentional violation, the 'actual'
> incident report would equally consider how accurate that was.
>
>
>
> Recall that the approach to incident reporting is not punitive - it's to
> make sure that we're addressing systemic gaps and issues, that we've
> understood the issues, and have the available data to assess the impact,
> risk, and any patterns of issues. The incident reporting template is one
> way to provide that data in a structured way and to gather feedback.
>
>
>
> I think a minimum next step is to move from the abstract discussion to the
> concrete: imagine you went forward on Jan 15 and had to file an incident
> report. Write the report like that. Include the timeframes, affected
> certificates, impact, root causes, remediation plans, etc. Having a
> complete presentation of what the discussion is about seems critical to
> having that discussion, because it would be unreasonable to expect
> information to trickle in and new customers or use cases added as the
> discussion progresses.
>
>
>
> Thus there's a balance to be struck: Treating each hypothetical as a
> "separate" incident report runs the risk of being considered in isolation,
> ignoring both the systemic gaps and the cumulative risk. At the same time,
> treating it as a "singular" incident report tries to paint all problems in
> the same stroke, and can overlook distinct systemic issues. Both cases run
> the risk of "scope creep", which is constantly adding or expanding the
> scope, which is as well received in legitimate incident reports as it is
> hypothetical (which is to say: not well). Perhaps the best analogy is to
> that of subordinate CAs: each time a subordinate has an issue, that's an
> incident report, and a pattern of issues at distinct subordinates is
> equally a concerning issue for the parent CA. You don't want to loop all
> distinct subordinates into one issue, but you also don't want to lose sight
> of the systemic issues with the parent.
>
>
>
> Beyond that framing and execution, it seems useful to suggest that any
> timeline about underscores should at least acknowledge Ballot 202 in June
> 2017 and any/all steps the CA took leading up to and following SC12.
>
>
>
> None of this is radically new or should be surprising: DigiCert and other
> CAs have already had similar conversations in discussing other matters of
> BR compliance and revocation. All of these have become part of the CA's
> record of incidents. When the CA proposes extending revocation timelines, a
> discussion of the facts, risks, scope, and patterns play a core part in any
> discussion in determining the short term acceptability of the proposal, and
> unquestionably all factor in to any long-term discussions that may later
> happen.
>
>
>
> The one last closing thought is that I think we're in the waning days for
> when such hypothetical issues or concrete delay proposals can or should be
> discussed. Given the many discussions that have been had regarding
> revocation - regarding technical non-compliance, compromised keys, weak
> validation, etc - the argument that "replacing a cert is hard" is not
> really going to be acceptable anymore without demonstration about what
> steps are being taken by CAs and Subscribers to mitigate that risk (such as
> automation) and communicate expectations (such as in Subscriber Agreements
> or Terms of Sale). I don't think we want to go through 2019, and certainly
> not come out of it, having the same conversations we've been having in
> 2018. The best way to prevent that is for CAs to take clear steps to work
> to resolve these issues with their customers, so that it never becomes an
> issue for them, or their CA, in the first place. CAs that aren't able to
> demonstrate steps towards that in future discussions are unlikely to be
> looked upon too favorably if there are future incident reports.
>
>
>
> On Tue, Dec 18, 2018 at 5:43 PM Jeremy Rowley via dev-security-policy <
> [email protected]> wrote:
>
> The total number of certs impacted is about 2200. Just more info.
>
> -----Original Message-----
> From: dev-security-policy <[email protected]>
> On
> Behalf Of Jeremy Rowley via dev-security-policy
> Sent: Tuesday, December 18, 2018 3:28 PM
> To: mozilla-dev-security-policy
> <[email protected]>
> Subject: Underscore characters
>
> We're looking at the feasibility of replacing the certificates with
> underscore characters by Jan 15th. Revoking all of the certificates will
> cause pretty bad outages. We're prepared to revoke them but would like to
> discuss (before the date) what should happen if we don't revoke. There are
> about 15 customers (which I can't disclose the names yet but am working on
> the list of certs). The number of certificates range between 1700-100
> certificates per customer.
>
>
>
> The primary reason for this is every one of these organization are in a
> holiday blackout.  The blackout periods end between Jan 12-Feb 15. Can we
> start this discussion now on what this means? I'll provide certificate
> lists
> as I have a timeline on when they plan on replacing.
>
>
>
> Jeremy
>
>
>
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