I don't follow your argument about torturing the meaning of "provide". The
other analogous instances of the word "provide" in the BRs are:
- The CA SHALL provide a process for Subscribers to request revocation of
their own Certificates.
- The CA SHALL provide Subscribers... with clear instructions for reporting
suspected Private Key Compromise...
- the CA SHALL update the information provided via an Online Certificate
Status Protocol...
- the CA SHALL provide a Random Value...

All of these are items that a CA provides either a) statically, in the case
of processes and instructions, or b) reactively to a query by the
subscriber or relying party, in the case of OCSP and random values. None of
these have the meaning "proactively place in the inbox of the party to whom
information is provided". In an automated environment such as ACME, where
the "preliminary report" and the final revocation decision are identical,
an updated OCSP response is all that is necessary to satisfy the obligation
to provide a report on the CA's findings.

Aaron

On Wed, Dec 8, 2021 at 9:42 PM Matt Palmer <[email protected]> wrote:

> On Wed, Dec 08, 2021 at 01:28:12PM -0800, Aaron Gable wrote:
> > The language being used in this discussion so far does not seem to
> reflect
> > the actual text of the BRs. A CA is currently under no obligation to
> > "notify" the subscriber prior to revocation. Rather, a CA is under
> > obligation to "work with the Subscriber... to establish whether or not
> the
> > certificate will be revoked".
>
> I agree that "work with" does not absolutely require prior communication
> with the subscriber, if the subscriber agreement allows the CA to revoke.
> However, the first sentence of 4.9.5 remains problematic.  It says that
> "the
> CA SHALL investigate the [...] Certificate Problem Report and provide a
> preliminary report on its findings to [...] the Subscriber".
>
> I haven't been able to come up with an interpretation of that sentence
> which
> allows the CA to avoid collecting reliable contact information for all
> subscribers, short of some *really* tortured interpretations of the word
> "provide".  Torturing that word would probably have some unfortunate
> consequences, too, because it's used elsewhere in the BRs.
>
> - Matt
>
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