On Fri, Jun 14, 2019 at 4:12 PM Jakob Bohm via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> In such a case, there are two obvious solutions:
>
> A. Trademark owner (prompted by applicant) provides CA with an official
>    permission letter stating that Applicant is explicitly licensed to
>    mark the EV certificate for a specific list of SANs and and Subject
>    DNs with their specific trademark (This requires the CA to do some
>    validation of that letter, similar to what is done for domain
>    letters).


This process has been forbidden since August 2018, as it is fundamentally
insecure, especially as practiced by a number of CAs. The Legal Opinion
Letter (LOL) has also been discussed at length with respect to a number of
problematic validations that have occurred, due to CAs failing to exercise
due diligence or their obligations under the NetSec requirements to
adequately secure and authenticate the parties involved in validating such
letters.


Letter needs to be reissued for end-of-period cert
>    renewals, but not for unchanged early reissue where the cause is not
>    applicant loss of rights to items.  For example, the if the Heartbleed
>    incident had occurred mid-validity, the web server security teams
>    could get reissued certificates with uncompromised private keys
>    without repeating this time consuming validation step.


EV certificates require explicit authorization by an authorized
representative for each and every certificate issued. A key rotation event
is one to be especially defensive about, as an attacker may be attempting
to bypass the validation procedures to rotate to an attacker-supplied key.
This was an intentional design by CAs, in an attempt to provide some value
over DV and OV certificates by the presumed difficulty in substituting them.
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