All,

This is to announce the beginning of the public discussion phase of the
Mozilla root CA inclusion process (
https://wiki.mozilla.org/CA/Application_Process#Process_Overview - Steps 4
through 9) for an inclusion request filed by Certainly, LLC (Bug # 1727941
<https://bugzilla.mozilla.org/show_bug.cgi?id=1727941>, CCADB Case # 829
<https://ccadb-public.secure.force.com/mozilla/PrintViewForCase?CaseNumber=00000829>)
for the following two (2) root CA certificates:

*Certainly Root R1 (websites trust bit only)*

https://crt.sh/?sha256=77B82CD8644C4305F7ACC5CB156B45675004033D51C60C6202A8E0C33467D3A0

http://root-r1.certainly.com

*Certainly Root E1 **(websites trust bit only)*

https://crt.sh/?sha256=B4585F22E4AC756A4E8612A1361C5D9D031A93FD84FEBB778FA3068B0FC42DC2

http://root-e1.certainly.com/

Certainly is currently the subject of an ongoing public discussion in
relation to GoDaddy’s intent to cross-sign two issuing CAs to be operated
by Certainly. In that proceeding, Certainly would be an external,
third-party operator of non-technically-constrained issuing CAs. In this
proceeding, Certainly’s two roots would be added to NSS and Firefox as
trust anchors with the websites trust bit and Certainly would be a root CA
operator. The information collected and reviewed by GoDaddy, me, and others
during the cross-signing application proceeding (Bug #1755851
<https://bugzilla.mozilla.org/show_bug.cgi?id=1755851>) is useful in
considering this root inclusion request, as are comments and information
presented in that public discussion (
https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/bEnn98Dajzc/m/32NwZHWSAAAJ
).

*Repository:* The Certainly document repository is located here:

https://www.certainly.com/repository/

*Relevant Policy and Practices Documentation: *

Certificate Policy / Certification Practice Statement, v. 1.3, dated March
1, 2022

https://www.certainly.com/repository/CertainlyCP-CPS.pdf

*Self-Assessments and CPS Reviews* are located as attachments in the
following two (2) bugs:  Bug # 1727941
<https://bugzilla.mozilla.org/show_bug.cgi?id=1727941> and Bug # 1755851
<https://bugzilla.mozilla.org/show_bug.cgi?id=1755851>.  Specifically,
https://bugzilla.mozilla.org/attachment.cgi?id=9270636 (review performed by
me on 4-Mar-2022) and https://bugzilla.mozilla.org/attachment.cgi?id=9267213
(Certainly’s updated Self-Assessment, dated 9-Mar-2022).

*Value-vs-Risk Justification from Certainly* -
https://bugzilla.mozilla.org/attachment.cgi?id=9270080

*Audits:*  Point-in-time audits (dated June 30, 2021) were performed by
Schellman & Company in accordance with WebTrust Principles and Criteria for
Certification Authorities, v. 2.2.1, and WebTrust SSL Baseline with Network
Security, v. 2.5.  See https://www.certainly.com/repository/audit/index.html

*Incidents*

Certainly has no open incidents in Bugzilla.

In the past 12 months, there were two (2) incidents involving Certainly,
which are now closed as fixed:

1732745 <https://bugzilla.mozilla.org/show_bug.cgi?id=1732745>
     Root
CRL validity period exceeded maximum stated period by one second

1752452 <https://bugzilla.mozilla.org/show_bug.cgi?id=1752452>              TLS
Using ALPN TLS Version and OID

I have no further questions or concerns about Certainly’s inclusion
request. However, I urge anyone with concerns or questions to raise them on
this list by replying directly in this discussion thread. Likewise, a
representative of Certainly must promptly respond directly in the
discussion thread to all questions that are posted.

This email begins the 3-week comment period, which I’m scheduling to close
on or about April 25, 2022, after which, if no concerns are raised, we will
close the discussion and the request may proceed to the approval phase
(Step 10).

Sincerely yours,

Ben Wilson

Mozilla Root Program Manager

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