Hi everyone, 

Quick question! Will Certainly be offering a public ACME CA for use by 
everyone (à la Let's Encrypt), or will this be for Fastly customer use only?

Cheers, 

Scott. 

On Thursday, 17 February 2022 at 06:10:31 UTC [email protected] wrote:

> This is to announce and begin public discussion of GoDaddy’s intent to use 
> its publicly trusted Starfield Root Certificate Authority - G2 (
> https://crt.sh/?caid=796) to create two new external subordinate CA 
> certificates to be operated and maintained by Certainly, LLC.  These will 
> be cross-certificates sharing their respective key pairs with subordinate 
> CA certificates signed by two Certainly Root CAs that are pending inclusion 
> (https://bugzilla.mozilla.org/show_bug.cgi?id=1727941). 
>
> In accordance with Mozilla Root Store Policy, Section 8 - CA Operational 
> Changes 
> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#8-ca-operational-changes>
>  
> for new program participants and at the instruction of Process for Review 
> and Approval of Externally Operated Subordinate CAs 
> <https://wiki.mozilla.org/CA/External_Sub_CAs_not_Technically_Constrained#Process_for_Review_and_Approval_of_Externally_Operated_Subordinate_CAs_that_are_Not_Technically_Constrained>
>  
> we have created Bugzilla Bug 1755851 
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1755851> and are initiating 
> this formal discussion period.
>
> Certainly is a wholly owned subsidiary of Fastly, Inc. 
> <https://www.fastly.com/>, a cloud service provider headquartered in the 
> USA. Certainly plans to issue certificates to existing Fastly customers. 
> The two Certainly subordinate CAs will issue publicly-trusted DV TLS server 
> certificates. More details may be found in Certainly’s root inclusion 
> case in CCADB 
> <https://ccadb-public.secure.force.com/mozilla/PrintViewForCase?CaseNumber=00000829>.
>  
> Certainly has performed a CA Compliance Self-Assessment 
> <https://bugzilla.mozilla.org/attachment.cgi?id=9239293> and has 
> committed to adhere to all Mozilla requirements, Baseline Requirements of 
> the CA/Browser Forum, and the GoDaddy (Starfield Technologies) CP/CPS.
>
> All the operational services related to Certainly’s Subscribers will be 
> performed by Certainly, including processing of certificate applications, 
> certificate issuance, certificate publishing, certificate status services, 
> and certificate management. Certainly has implemented the open-source 
> Boulder CA <https://github.com/letsencrypt/boulder> and interacts with 
> Applicants and Subscribers via an ACME 
> <https://datatracker.ietf.org/doc/html/rfc8555> API endpoint.  Certainly 
> has applied for inclusion 
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1727941> as a root CA to 
> Mozilla and a number of other root store programs, requesting inclusion of 
> two root certificates. Both will be used exclusively to issue DV TLS 
> certificates, with the distinction that one root will anchor an RSA 
> hierarchy and the other will anchor an ECDSA hierarchy. These roots, as 
> well as the two corresponding subordinate CAs that are constrained to TLS 
> usages, have been disclosed in CCADB.
>
> Certainly has received the following unqualified audit reports (see Bug 
> 1755851 <https://bugzilla.mozilla.org/show_bug.cgi?id=1755851> for full 
> reports) from the WebTrust Practitioner, Schellman, LLC:
>
>    - WebTrust for CAs point-in-time dated June 30, 2021 
>    - WebTrust SSL Baseline with NCSSRs point-in-time dated June 30, 2021 
>    - WebTrust for CAs Key Lifecycle Management report (covering the 
>    period between key generation and type-1 audits) 
>
> Certainly will undergo WebTrust for CAs and WebTrust SSL Baseline with 
> NCSSRs period-of-time audits no later than June 30, 2022, covering a period 
> beginning July 1, 2021. Certainly has further committed to ongoing WebTrust 
> audits for the 10-year lifetime of the cross-signed certificates.
>
> As operator of a Mozilla-trusted root CA (and a trusted root in other 
> browser root store programs), we recognize that through this cross-sign 
> event, we are ultimately accountable for any actions taken by the Certainly 
> intermediates which will inherit our trust and have worked closely with 
> Certainly to perform due diligence activities including the review of the 
> Certainly CP/CPS 
> <https://www.certainly.com/repository/CertainlyCP-CPS.pdf>, Subscriber 
> Agreement 
> <https://www.certainly.com/repository/CertainlySubscriberAgreement.pdf>, 
> and Relying Party Agreement 
> <https://www.certainly.com/repository/CertainlyRelyingPartyAgreement.pdf> 
> against CA/B forum requirements, GoDaddy Policies, and Mozilla policies. We 
> have also reviewed Certainly’s CA Compliance Self-Assessment and 
> operational practices, interviewed Certainly personnel, and reviewed the 
> external audit opinions to verify appropriate scope of coverage and 
> conformance with requirements as expected. Currently and following the 
> proposed cross-sign event, we will continue working closely with Certainly 
> to oversee ongoing compliance efforts.
>
> Of note, Certainly has filed two Mozilla incident reports to date (listed 
> below) which we have followed and reviewed with Certainly. It is our 
> expectation that the second bug be resolved prior to any cross-sign event.
>
>    - Root CRL validity period exceeds maximum by one second 
>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1732745>  (27-September 
>    2021) 
>    - TLS Using ALPN TLS Version and OID 
>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1752452> (27-January 
>    2022) 
>
> This email begins a 3-week comment period, after which Mozilla is expected 
> to consider approval of GoDaddy’s request.
>
> Best,
>
> Brittany Randall
>

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