On Fri, Mar 8, 2019 at 7:55 PM Matthew Hardeman via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> On Fri, Mar 8, 2019 at 9:49 PM Ryan Sleevi <r...@sleevi.com> wrote:
>
> > I consider that only a single CA has represented any ambiguity as being
> > their explanation as to why the non-compliance existed, and even then,
> > clarifications to resolve that ambiguity already existed, had they simply
> > been sought.
> >
>
> Please contemplate this question, which is intended as rhetorical, in the
> most generous and non-judgmental light possible.  Have you contemplated the
> possibility that only one CA attempted to do so because you've stated your
> interpretation and because they're subject to your judgement and mercy,
> rather than because the text as written reflects a single objective
> mechanism which matches your own position?
>

Matthew,

I honestly doubt so.  It seems that one CA software vendor had a buggy
implementation but we know this is not universal.  For example, see
https://github.com/r509/r509/blob/05aaeb1b0314d68d2fcfd2a0502f31659f0de906/lib/r509/certificate_authority/signer.rb#L132
 and https://github.com/letsencrypt/boulder/blob/master/ca/ca.go#L511 are
open source CA software packages that clearly do not have the issue.
Further at least one CA has publicly stated their in-house written CA
software does not have the issue.

I know, as the author of cablint, that the main reason I didn't have any
confusion.  I didn't add more checks because of the false positive rate
issue; if I checked for 64 or more bits, it would be wrong 50% of the
time.  The rate is still unacceptable with even looser rules; in 1/256
cases the top 8 bits will all be zero, leading to a whole the serial being
a whole byte shorter.

I do personally think that the CAs using EJBCA should not be faulted here;
their vendor added an option to be compliant with the BRs and it was very
non-obvious that it had a bug in the implementation.  Based on my
experience with software development, we should be encouraging CAs to use
well tested software rather than inventing their own, when possible.

Thanks,
Peter
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