On Tue, Dec 07, 2021 at 07:56:46PM +0000, Corey Bonnell wrote:
> Hi Matt,
> 
> > My reading of that specific requirement is that the subscriber agreement
> > must contain that stipulation, and *if* a subscriber receives an
> > instruction and fails to respond to it, they are in breach of the
> > agreement.  I don't read it as requiring the CA to issue instructions in
> > any particular circumstance.
> 
> BR section 4.9.5 has specific obligations for the CA to notify the
> Subscriber of pending revocations due to Key Compromise, etc.

I think you can reasonably read 4.9.5 even broader than that, since it
requires communication with the subscriber *any* time a Certificate Problem
Report is received.

> BR 9.6.3 (7) provides assurance that the Subscriber will respond to such
> communications to ensure timely replacement of certificates.

Hmm, I don't think 9.6.3(7) is *quite* that specific (as it merely says that
subscriber must "respond to the CA's instructions", rather than talking
about timely replacement of certificates specifically) but it's not germane
to the point at hand, so I don't see a need to debate the point extensively.

> However, if the CA does not collect any Subscriber contact information,
> then the CA cannot execute on its obligations to notify the Subscriber.

Agreed.

> In turn, if
> such communication from the CA cannot be sent to the Subscriber due to
> lack of contact information, then it follows that the Subscriber will not
> be able to fulfill their obligation for 9.6.3 (7).

This is where I'm still getting stuck.  I can't see how a subscriber's
obligation to respond is relevant until they've received instructions from
the CA.  If we agree that I have to give you $20 cash each time we see each
other, and I then go hide in a cave where you can't find me, I don't ever
need to have $20 in my pocket.

> Therefore, I believe it is incumbent that CAs collect information for at
> least one method of contact so that both the CA-to-Subscriber notification
> obligation and the Subscriber's obligation to respond to the CA can be
> fulfilled.

I agree that 4.9.5 requires a CA to collect and maintain contact information
for subscribers so they can fulfill their obligations.  I'm still not seeing
how 9.6.3 (7) requires the CA to do same, though -- it's too much of a
stretch for my ageing joints.

- Matt

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