I'm not trying to throw you under the bus here, but I think it's helpful if
you could highlight what new information you see being required, versus
that which is already required.

I think, yes, you're right that it's not well received if you go violate
the BRs and then, after the fact, say "Hey, yeah, we violated, but here's
why", and finding out that the reasons are met with a lot of skepticism and
the math being shaky, and you can see that from past incident reports it
doesn't go over well.

But it's also not well received if it's before, and the statement is "Our
customer thinks we should violate the BRs. What would happen if we did, and
what information do you need from us?". That gets into the moral hazard
that Matt spoke to, and is a huge burden on the community where the
expectation is that the CA says "Sorry, we can't do that".

So the assumption here is that, in all of this discussion, DigiCert's done
everything it can to understand the issue, the timelines, remediation, etc,
and has plans to address both each and every customer and the systemic
issues that have emerged. If that's not the case, then how are we not in
one of those two scenarios above? And if it is the case, isn't that
information readily available by now?

From the discussions on the incident reports, I feel like that's been the
heart of the questions; which is trying to understand what the root cause
is and what the remediation plan is. The statement "We'll miss the first
deadline, but we'll hit the second", but without any details about how or
why, or the steps being taken to ensure no deadlines are missed in the
future, doesn't really inspire confidence, and is exactly the same kind of
feedback that would be given post-incident.

On Thu, Dec 27, 2018 at 1:50 PM Jeremy Rowley via dev-security-policy <
[email protected]> wrote:

> There's a little bit of a "damned if you do, damned if you don't problem
> here". Wait until you have all the information? That's a paddlin'.  File
> before you have enough information? That's a paddlin'. I'd appreciate
> better guidance on what Mozilla expects from these incident reports
> timing-wise.
>
> -----Original Message-----
> From: dev-security-policy <[email protected]>
> On Behalf Of Jeremy Rowley via dev-security-policy
> Sent: Thursday, December 27, 2018 11:47 AM
> To: [email protected]
> Cc: [email protected]
> Subject: RE: Underscore characters
>
> The original incident report contained all of the details of the initial
> filing.  The additional, separated reports are trickling in as I get enough
> info to post something in reply to the updated questions. As the questions
> asked have changed from the original 7 in the Mozilla incident report,
> getting the info back takes time. Especially during the holiday season.
> We’re also working to close out as many without an exception as possible.
> Note that the deadline has not passed yet so all of these incident reports
> are theoretical (and not actually incidents) until Jan 15th. I gave the
> community the total potential number of certificates impacted and the total
> number of customers so we can have a community discussion on the overall
> risk and get public comments into the process before the deadline passes.
> I’m unaware of any policy at Mozilla or Google that provides guidance on
> how to file expected issues before they happen. If there is, I’d gladly
> follow that.
>
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