As mentioned in my previous email, we were waiting for iTrusChina to
complete its work on a monitoring system for CA signing operations
under Bugzilla
Bug #1712664 <https://bugzilla.mozilla.org/show_bug.cgi?id=1712664>. That
work has completed, and the bug is now closed.

Pursuant to Steps 9 and 10 of the inclusion process, I am hereby concluding
public discussion and declaring that it is Mozilla's intent to approve
iTrusChina's inclusion request. This begins a one-week last call for
objections through 3-November-2021, after which, if there are no further
questions or concerns, the request will be approved.

Thanks,

Ben




On Mon, Oct 4, 2021 at 3:00 PM Ben Wilson <[email protected]> wrote:

> *Summary of Discussion and Resulting Decisions or Action Items*
>
> Public discussion on the iTrusChina inclusion application began on April
> 7, 2021.[1] iTrusChina is seeking inclusion of an RSA root and an ECC root
> to be used for websites, including issuance of EV TLS server certificates.
> Progress on this inclusion request has been tracked in Bugzilla #1554846.[2]
>
> In relation to the public discussion of TunTrust’s application, also
> announced on April 7, we received comments from Ryan Sleevi and others that
> new CAs might present limited value and pose unnecessary risk to Mozilla
> users.[3] So, on April 20, I announced that I was working on follow-up
> questions regarding their added value to users vs. added risk.[4] In May,
> we announced a position statement on our wiki titled, “Quantifying
> Value”.[5] Accordingly, a new applicant “must present an explanation of the
> benefits to our users so that the community can identify, measure, value,
> and understand the benefits of including the root certificate and determine
> whether it is worth the risk of including it. These applicant-provided
> explanations cannot just be marketing fluff or mere self-promotion.
> Justifications must be detailed, objective, and supported by data to
> establish credible facts and create legitimacy and trust.”
>
> On July 2, iTrusChina submitted a Value Justification.[6] On August 12, I
> circulated a brief summary and requested a more detailed operations
> budget[7], which was provided by iTrusChina.[8] The budget shows an
> approximate $1.83M in 2021 operating expenses and $309.5K for 2021 in
> capital expenditures.
>
> More recently, I conducted a review[9] and follow-up review[10] of the
> iTrusChina CPS for compliance with the Extended Validation Guidelines, and
> I found the updates to its CPS satisfactory.
>
> *Other Action Items*
>
> During the discussion period, it was noted by Andrew Ayer that the
> signatures on iTrusChina’s ARL (CRLs for CAs signed by the root CA) were
> failing verification.[11]  “Our offline CA's ARL system has a design bug,
> it causes the new extension item to not be added to the original signature,
> resulting in the signature verification failed.”[12]
>
> iTrusChina worked on this bug #1712664 by adding signature verification
> steps, and it reported at the beginning of August that they had completed
> this work for the system generating CRLs/ARLs.[13] While Bug #1712664 is
> still open to finish work on monitoring and detection of CA certificate
> signature issues, I believe there are no other action items open.
>
> Under Steps 7 and 8 of the Application Process[14], I will await
> completion of full testing of these enhancements to iTrusChina’s CA system.
> I do not believe a second round of public discussion will be needed, and I
> will await closing public discussion and giving notice of intent to approve
> iTrusChina’s application until then.
>
> Thanks,
>
> Ben
>
>
>
> [1]
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/4bWqkOwhzCc/m/a8dDrSjSBQAJ
>
> [2] https://bugzilla.mozilla.org/show_bug.cgi?id=1554846
>
> [3]
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/dTTp4ZfUW34/m/FssiRIHWBQAJ
>
> [4]
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/4bWqkOwhzCc/m/0xjkC8JNAwAJ
>
> [5] https://wiki.mozilla.org/CA/Quantifying_Value
>
> [6] https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c47
>
> [7]
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/4bWqkOwhzCc/m/WZFkYNJqAgAJ
>
> [8] https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c48
>
> [9] https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c50
>
> [10] https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c53
>
> [11]
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/4bWqkOwhzCc/m/4v2pNhrNAAAJ
>
> [12] https://bugzilla.mozilla.org/show_bug.cgi?id=1712664
>
> [13] https://bugzilla.mozilla.org/show_bug.cgi?id=1712664#c18
>
> [14] https://wiki.mozilla.org/CA/Application_Process#Process_Overview
>
>
>
> On Thu, Sep 23, 2021 at 10:28 AM Ben Wilson <[email protected]> wrote:
>
>> All,
>> I have completed an EV-Guidelines review [1] of iTrusChina's updated CPS,
>> v.1.4.7 [2].
>> I will be closing public discussion and writing up a summary of the
>> public discussion.
>> Thanks,
>> Ben
>> [1] https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c53
>> [2] https://www.itrus.com.cn/uploads/soft/210923/2-2109231I106.pdf
>>
>> On Sat, Sep 18, 2021 at 3:17 AM yutian zheng <[email protected]>
>> wrote:
>>
>>> Hi Ben,
>>>
>>> We have revised a new version of CPS based on your comments and are
>>> going through the internal release process, which will be updated to our
>>> official website for review within a week.
>>> Regarding the issue of the EV certificate insurance policy, iTrusChina
>>> decides its insurance policies based on its business development and the
>>> business development of Chinese insurance companies. For the EV
>>> certificate, iTrusChina has passed the financial audit of a third-party
>>> audit company and has reserved the relevant insurance amount for the
>>> planned EV customers. Currently iTrusChina does not purchase relevant
>>> commercial insurance.
>>>
>>> Regards,
>>> vTrus Team
>>>
>>> 在2021年9月16日星期四 UTC+8 上午1:36:48<[email protected]> 写道:
>>>
>>>> All,
>>>> This past week, I posted my EV Guidelines review of iTrusChina's CPS to
>>>> Bugzilla. (https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c50).
>>>> I expect that iTrusChina will want to update its CPS and address the EV
>>>> comments in order to pursue EV enablement of its roots. Then I will close
>>>> and summarize the public discussion, or ask follow-up questions, if
>>>> necessary.
>>>> Ben
>>>>
>>>> On Fri, Sep 10, 2021 at 2:57 PM Ben Wilson <[email protected]> wrote:
>>>>
>>>>> All,
>>>>>
>>>>> In preparing my summary of the public discussion of iTrusChina's
>>>>> application for inclusion of its RSA and ECC roots with the websites trust
>>>>> bit enabled, I noted that iTrusChina is seeking enablement of EV. Last
>>>>> September, I had conducted a review of iTrusChina's CPS, but at that time 
>>>>> I
>>>>> had not been checking specifically for compliance with the CA/Browser
>>>>> Forum’s EV Guidelines. See
>>>>> https://wiki.mozilla.org/CA/Required_or_Recommended_Practices#CP.2FCPS_Documents_will_be_Reviewed.21.
>>>>> Instead of providing a summary of discussion and resulting decision and
>>>>> action items, which I had intended to do today, I have decided to review
>>>>> the CPS for compliance with the EV Guidelines, as I have done more 
>>>>> recently
>>>>> with other applicants' CPSes. I'll post my review to the Bugzilla Bug
>>>>> #1554846 <https://bugzilla.mozilla.org/show_bug.cgi?id=1554846> as
>>>>> soon as it's ready.
>>>>>
>>>>> Thanks,
>>>>>
>>>>> Ben
>>>>>
>>>>>
>>>>> On Tue, Sep 7, 2021 at 9:28 PM Ben Wilson <[email protected]> wrote:
>>>>>
>>>>>> All,
>>>>>>
>>>>>> My review of CPS v. 1.4.6 and other comments appear inline below.
>>>>>>
>>>>>> On Wed, Aug 25, 2021 at 12:48 AM yutian zheng <[email protected]>
>>>>>> wrote:
>>>>>>
>>>>>>> Hi Ryan,
>>>>>>>
>>>>>>> Thank you very much for these questions, and we have checked our
>>>>>>> CP/CPS and corresponding business for these items, the answers are as
>>>>>>> follows:
>>>>>>>
>>>>>>> *1.      **Although the CCADB Policy does not require CAs make
>>>>>>> their CP/CPS authoritative in English, it does require that the CA 
>>>>>>> attest
>>>>>>> the information is not materially different. In their CPS, 1.2, they
>>>>>>> clearly state that the English version is not authoritative, and that in
>>>>>>> any conflicts, the Chinese version prevails, but there's no such 
>>>>>>> assurance
>>>>>>> about equivalence.*
>>>>>>>
>>>>>>> iTrusChina’s CP/CPS has a strict Chinese and English correspondence,
>>>>>>> which can ensure that there is no substantial difference in 
>>>>>>> information. We
>>>>>>> will modify the description here in the new version of CP/CPS.
>>>>>>>
>>>>>>> *New description: *The Chinese version of this CPS is issued.
>>>>>>> iTrusChina sincerely guarantees that there is no materially difference
>>>>>>> between the Chinese and English versions of the information.
>>>>>>>
>>>>>> I see that this change has been made in version 1.4.6 of the CPS. As
>>>>>> a minor matter of English grammar, in future versions, please make a 
>>>>>> change
>>>>>> of "materially" to "material".
>>>>>>
>>>>>>> *2.      **Section 3.1.6 states both that "Certificates issued by
>>>>>>> iTrusChina does not contain any trademarks or other information which 
>>>>>>> may
>>>>>>> infringe other parties' rights" and that "iTrusChina don't validate
>>>>>>> trademark right or legal disputes when processing applications", 
>>>>>>> which...
>>>>>>> seems to be conflicting.*
>>>>>>>
>>>>>>> We will modify the description in the next version of CP/CPS.
>>>>>>>
>>>>>>> *New description: *iTrusChina does not verify an Applicant’s right
>>>>>>> to use a trademark and does not resolve trademark disputes.
>>>>>>>
>>>>>>   I see that this change has been made in version 1.4.6 of the CPS.
>>>>>>
>>>>>>> *3.      **Section 3.2.2.6 has an interesting statement regarding
>>>>>>> which entities are allowed to obtain wildcards; seemingly preventing 
>>>>>>> them
>>>>>>> from DV certificates. This seems unfortunate and unnecessary, and while 
>>>>>>> not
>>>>>>> prohibited, is at least something that stands out as perhaps misaligned 
>>>>>>> in
>>>>>>> goals / understanding of the purpose of TLS certificates.*
>>>>>>>
>>>>>>> The description of 3.2.2.6 is indeed ambiguous and we will modify
>>>>>>> it. In fact, we are issuing DV wildcard certificates.
>>>>>>>
>>>>>>> *New description: *Regarding a wildcard domain name, iTrusChina
>>>>>>> verifies the domain name on the right side of the wildcard to ensure 
>>>>>>> that
>>>>>>> the domain name is clearly owned by the applicant.
>>>>>>>
>>>>>> I see that this change has been made in version 1.4.6 of the CPS.
>>>>>>
>>>>>>> *4.      **Section 3.2.2.6 also includes an interesting clause "If
>>>>>>> necessary, iTrusChina needs to adopt other independent authentication
>>>>>>> methods to confirm the ownership of a domain name." It's unclear if 
>>>>>>> that's
>>>>>>> meant in addition to 3.2.2.4, or in lieu of 3.2.2.4.*
>>>>>>>
>>>>>>> We only use the domain verification method mentioned in 3.2.2.4, so
>>>>>>> we think our description is indeed ambiguous, and we will delete it in 
>>>>>>> the
>>>>>>> next version of CP/CPS.
>>>>>>>
>>>>>> The sentence mentioned above has been deleted in version 1.4.6 of the
>>>>>> CPS.
>>>>>>
>>>>>> *5.      **Section 3.2.2.8 has a real red flag: "If the tag 'iodef'
>>>>>>> exists in CAA records, iTrusChina will determine whether to issue the
>>>>>>> certificate after communicating with the applicant".*
>>>>>>>
>>>>>>>          *It's unclear if they're treating this as permission to
>>>>>>> issue if the tag exists, which would be a BR violation.*
>>>>>>>
>>>>>>>          It*'s unclear if they're redefining the semantics of iodef
>>>>>>> (which is used for exception reports / violations, not for permission)*
>>>>>>>
>>>>>>> Our description of iodef is incorrect and will be revised in the
>>>>>>> next version of CP/CPS.
>>>>>>>
>>>>>>> *New description: *When the certificate requests or issuances
>>>>>>> violate the security policy of the Issuer or the FQDN holder,if the tag
>>>>>>> "iodef" exists in CAA records, iTrusChina will dispatch reports of such
>>>>>>> issuance requests to the contact(s) stipulated in the CAA iodef 
>>>>>>> record(s).
>>>>>>>
>>>>>> I see that this change has been made in version 1.4.6 of the CPS.
>>>>>>
>>>>>>> *6.      **Section 6.1.1.1 has a similar red flag "Since China has
>>>>>>> strict administration requirements on cryptographic products, FIPS 140-2
>>>>>>> Standard is not a standard approved and supported by the State 
>>>>>>> Cryptography
>>>>>>> Administration, FIPS 140-2 Standard is only enforced as a reference,
>>>>>>> selectively applicable on the premise of passing the evaluation and
>>>>>>> certification of the State Cryptography Administration and being 
>>>>>>> licensed
>>>>>>> by national cryptography administration policies."*
>>>>>>>
>>>>>>>    *This reasonably calls into question the safety and security of
>>>>>>> the CAs' private keys. Similar remarks are found within Section 6.2.1.*
>>>>>>>
>>>>>>> China has corresponding technology and testing standards for HSM.
>>>>>>> For compliance reasons, we must use HSM products from manufacturers
>>>>>>> licensed by the State Cryptography Administration. This requirement is 
>>>>>>> also
>>>>>>> applicable to other licensed CAs in China. Our supplier's HSM products
>>>>>>> obtained FIPS 140-2 level 3 certification in 2019 (see attachment). If
>>>>>>> necessary, we can replace HSM later.
>>>>>>>
>>>>>> The FIPS 140-2 record provided by iTrusChina for the Sansec
>>>>>> cryptomodule was reviewed. I.e.
>>>>>> https://csrc.nist.gov/projects/cryptographic-module-validation-program/certificate/3350.
>>>>>> No related changes were made to the CPS.
>>>>>>
>>>>>>> *7.      **Section 6.1.1.2 "If a subscriber submits a PKCS#10 file
>>>>>>> of a weak algorithm during application, iTrusChina will reject the
>>>>>>> application and recommend the user to generate a new key pair" - this 
>>>>>>> proof
>>>>>>> of possession provides no benefit in the context of TLS, and so this is 
>>>>>>> a
>>>>>>> rather silly check. This has been discussed in the past here on 
>>>>>>> m.d.s.p.*
>>>>>>>
>>>>>>> There are some problems with our statement here. What we meant to
>>>>>>> express is that we will reject the application if we find that the
>>>>>>> subscriber is using a Debian weak key (as described in BR6.1.1.3), we 
>>>>>>> will
>>>>>>> modify it in the next version CP/CPS.
>>>>>>>
>>>>>> The sentence in section 6.1.1.2, quoted above, has been replaced by
>>>>>> "iTrusChina will reject the application if it finds that the subscriber 
>>>>>> is
>>>>>> using a Debian weak key."
>>>>>>
>>>>>>>  *8.      **Section 6.3.2 makes it clear that intermediates are
>>>>>>> generated very long (25 years), while the clear trend of industry has 
>>>>>>> been
>>>>>>> moving towards shorted lived intermediates, and regularly rotating 
>>>>>>> them, to
>>>>>>> ensure necessary certificate agility and robustness.*
>>>>>>>
>>>>>>> At present, we have not formulated a policy for regular replacement
>>>>>>> of intermediate roots. Considering the agility and robustness of the
>>>>>>> certificate, we will issue new intermediate root certificates with a
>>>>>>> shorter age in the future.
>>>>>>>
>>>>>> It will be good for iTrusChina to implement a process to replace
>>>>>> intermediate CA certificates more frequently, even though the CPS says 
>>>>>> that
>>>>>> they can have a validity of up to 25 years.
>>>>>>
>>>>>>> *9.      **Section 7.1.2 is not that useful (e.g. the EKU for
>>>>>>> intermediates just says (paraphrased) "We'll put something here after
>>>>>>> 2019-01-01"). Similarly the notBefore/notAfter remarks.*
>>>>>>>
>>>>>>> iTrusChina plans to generate some intermediate CA certificates after
>>>>>>> 2019-01-01, and the intermediate certificates generated before this do 
>>>>>>> not
>>>>>>> contain the EKU extension. According to the requirements of Mozilla's 
>>>>>>> Root
>>>>>>> policy, the intermediate certificate generated after 2019-01-01 needs to
>>>>>>> include the EKU extension, so we have added this description.
>>>>>>>
>>>>>>> In the section 7.1.2 table in iTrusChina's future CPS, it should
>>>>>> state that subordinate CA certificates will have EKUs, which shall only 
>>>>>> be
>>>>>> the serverAuth and clientAuth EKUs.
>>>>>>
>>>>>>> 10.   Regarding the issue of EV Certificates Registration Agency
>>>>>>> Disclosure, the data sources we disclose are not only EV certificates, 
>>>>>>> but
>>>>>>> also information sources for all other types of SSL certificates. The
>>>>>>> Unified Social Credit Code Certificate and Dun and Bradstreet are used 
>>>>>>> for
>>>>>>> the Subject field of the SSL certificate, iTrusChina's SSL business is
>>>>>>> currently only carried out in China, and D&B is only used to query
>>>>>>> applicants' English names. The third chapter of our document is 
>>>>>>> dedicated
>>>>>>> to EV Certificates Registration Agency Disclosure.
>>>>>>>
>>>>>> I am satisfied with this explanation. For anyone else's further
>>>>>> review, the relevant document is located here:
>>>>>> https://www.itrus.com.cn/uploads/soft/210401/2-2104011K954.pdf.
>>>>>>
>>>>>>> 11.   In addition, regarding
>>>>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1712664, we will
>>>>>>> complete the coding of the monitoring system this week, and then start 
>>>>>>> the
>>>>>>> system test next week. We are very grateful to Andrew for raising the
>>>>>>> question and Ryan's suggestions for improvement. These are very helpful 
>>>>>>> to
>>>>>>> us.
>>>>>>>
>>>>>> The progress of this work has been requested in the above-referenced
>>>>>> bug.
>>>>>>
>>>>>> In conclusion, aside from closing Bug 1712664, I believe there are
>>>>>> not open items remaining for iTrusChina to address. Step 6 of the
>>>>>> Application Process <https://wiki.mozilla.org/CA/Application_Process>
>>>>>> states, "A representative of Mozilla summarizes the discussion and
>>>>>> resulting decisions or action items," which I'll do on or before this
>>>>>> Friday, 10-Sept-2021. Step 7 of the Application Process contemplates that
>>>>>> the CA "completes action items resulting from the public discussion." I
>>>>>> don't think an additional second round of discussions  under Step 8 is
>>>>>> necessary. Then, under Step 9, "A representative of Mozilla concludes the
>>>>>> public discussion of the CA's request," which I'll plan to do next week
>>>>>> sometime.
>>>>>>
>>>>>> Thanks,
>>>>>> Ben
>>>>>>
>>>>>>
>>>>>>>
>>>>>>> Regards,
>>>>>>> vTrus Team
>>>>>>> 在2021年8月24日星期二 UTC+8 上午6:51:57<Ryan Sleevi> 写道:
>>>>>>>
>>>>>>>> Hi Ben,
>>>>>>>>
>>>>>>>> I'm using the CP/CPS they updated in
>>>>>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c33 and
>>>>>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1554846#c34
>>>>>>>>
>>>>>>>> There are a few things I wanted to call out and flag for further
>>>>>>>> discussion/consideration:
>>>>>>>>
>>>>>>>>    - Although the CCADB Policy does not require CAs make their
>>>>>>>>    CP/CPS authoritative in English, it does require that the CA attest 
>>>>>>>> the
>>>>>>>>    information is not materially different. In their CPS, 1.2, they 
>>>>>>>> clearly
>>>>>>>>    state that the English version is not authoritative, and that in any
>>>>>>>>    conflicts, the Chinese version prevails, but there's no such 
>>>>>>>> assurance
>>>>>>>>    about equivalence.
>>>>>>>>    - Section 3.1.6 states both that "Certificates issued by
>>>>>>>>    iTrusChina does not contain any trademarks or other information 
>>>>>>>> which may
>>>>>>>>    infringe other parties' rights" and that "iTrusChina don't validate
>>>>>>>>    trademark right or legal disputes when processing applications", 
>>>>>>>> which...
>>>>>>>>    seems to be conflicting.
>>>>>>>>    - Section 3.2.2.6 has an interesting statement regarding which
>>>>>>>>    entities are allowed to obtain wildcards; seemingly preventing them 
>>>>>>>> from DV
>>>>>>>>    certificates. This seems unfortunate and unnecessary, and while not
>>>>>>>>    prohibited, is at least something that stands out as perhaps 
>>>>>>>> misaligned in
>>>>>>>>    goals / understanding of the purpose of TLS certificates.
>>>>>>>>    - Section 3.2.2.6 also includes an interesting clause "If
>>>>>>>>    necessary, iTrusChina needs to adopt other independent 
>>>>>>>> authentication
>>>>>>>>    methods to confirm the ownership of a domain name." It's unclear if 
>>>>>>>> that's
>>>>>>>>    meant in addition to 3.2.2.4, or in lieu of 3.2.2.4.
>>>>>>>>    - Section 3.2.2.8 has a real red flag: "If the tag 'iodef'
>>>>>>>>    exists in CAA records, iTrusChina will determine whether to issue 
>>>>>>>> the
>>>>>>>>    certificate after communicating with the applicant".
>>>>>>>>       - It's unclear if they're treating this as permission to
>>>>>>>>       issue if the tag exists, which would be a BR violation.
>>>>>>>>       - If's unclear if they're redefining the semantics of iodef
>>>>>>>>       (which is used for exception reports / violations, not for 
>>>>>>>> permission)
>>>>>>>>    - Section 6.1.1.1 has a similar red flag "Since China has
>>>>>>>>    strict administration requirements on cryptographic products, FIPS 
>>>>>>>> 140-2
>>>>>>>>    Standard is not a standard approved and supported by the State 
>>>>>>>> Cryptography
>>>>>>>>    Administration, FIPS 140-2 Standard is only enforced as a reference,
>>>>>>>>    selectively applicable on the premise of passing the evaluation and
>>>>>>>>    certification of the State Cryptography Administration and being 
>>>>>>>> licensed
>>>>>>>>    by national cryptography administration policies."
>>>>>>>>       - This reasonably calls into question the safety and
>>>>>>>>       security of the CAs' private keys. Similar remarks are found 
>>>>>>>> within Section
>>>>>>>>       6.2.1.
>>>>>>>>    - Section 6.1.1.2 "If a subscriber submits a PKCS#10 file of a
>>>>>>>>    weak algorithm during application, iTrusChina will reject the 
>>>>>>>> application
>>>>>>>>    and recommend the user to generate a new key pair" - this proof of
>>>>>>>>    possession provides no benefit in the context of TLS, and so this 
>>>>>>>> is a
>>>>>>>>    rather silly check. This has been discussed in the past here on 
>>>>>>>> m.d.s.p.
>>>>>>>>    - Section 6.3.2 makes it clear that intermediates are generated
>>>>>>>>    very long (25 years), while the clear trend of industry has been 
>>>>>>>> moving
>>>>>>>>    towards shorted lived intermediates, and regularly rotating them, 
>>>>>>>> to ensure
>>>>>>>>    necessary certificate agility and robustness.
>>>>>>>>    - Section 7.1.2 is not that useful (e.g. the EKU for
>>>>>>>>    intermediates just says (paraphrased) "We'll put something here 
>>>>>>>> after
>>>>>>>>    2019-01-01"). Similarly the notBefore/notAfter remarks.
>>>>>>>>
>>>>>>>> Since they also issue EV certificates, and since it's mentioned in
>>>>>>>> the CP/CPS, I also checked out their disclosure of EV validation 
>>>>>>>> sources,
>>>>>>>> in https://www.itrus.com.cn/uploads/soft/210401/2-2104011K954.pdf
>>>>>>>>
>>>>>>>> It's difficult to see this complying with 11.1.3 - rather than
>>>>>>>> disclosing each Incorporating Agency / Registration Agency and 
>>>>>>>> associated
>>>>>>>> meta-data, they appear to have broken each field down into possible
>>>>>>>> permutations, leaving it unclear if it's subjected to combinatorial
>>>>>>>> explosion here. It also appears to demonstrate some confusion about 
>>>>>>>> how the
>>>>>>>> jurisdiction fields of an EV certificate work, judging by the
>>>>>>>> disclosure, although this could be my own confusion with respect to
>>>>>>>> jurisdictional issues in China. Without prejudice or opinion, it notes 
>>>>>>>> that
>>>>>>>> one of the sources is the Unified Social Credit Code Certificate. It 
>>>>>>>> also
>>>>>>>> lists Dun and Bradstreet as a source, which is highly questionable with
>>>>>>>> respect to EV certificates and the use of qualified information 
>>>>>>>> sources.
>>>>>>>>
>>>>>>>> Andrew previously noted
>>>>>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1712664 during the
>>>>>>>> public discussion, and that led to an opportunity for the CA to 
>>>>>>>> demonstrate
>>>>>>>> its incident detection and response capabilities. In the course of that
>>>>>>>> issue, it was determined that iTrusChina is running in-house developed 
>>>>>>>> CA
>>>>>>>> software and that the issue was caused by bugs within that software. 
>>>>>>>> Within
>>>>>>>> the bug, we see the unfortunately common struggle for CAs to go beyond
>>>>>>>> simply "respond to the symptom", and instead perform a deeper analysis 
>>>>>>>> for
>>>>>>>> the systems and processes that failed, and how to improve or strengthen
>>>>>>>> them.
>>>>>>>>
>>>>>>>> Although some of the issues highlighted above may very well be
>>>>>>>> communication issues, there certainly are unmistakable elements of red
>>>>>>>> flags of concern worth carefully consdering.
>>>>>>>>
>>>>>>>>

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