All,

I appreciate the thoughtful and constructive input that has been provided 
in this discussion. 

Based on the findings that were shared in this discussion thread 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/etbBho-VBQAJ>
 
and the responses from Trustcor’s Vice President of CA Operations, we 
believe that the following statements directly pertain to TrustCor’s 
position as a CA in Mozilla’s Root Program and have not been disputed:


   - 
   
   Measurement Systems is a company that has engaged in the distribution of 
   an SDK containing malware to Android users. [1]
   - 
   
   TrustCor operated a mail encryption product called MsgSafe which is 
   operationally tied to its CA unit. Specifically
   - 
      
      The same individual was responsible for the day to day operation of 
      both TrustCor’s CA business and MsgSafe. They are listed on TrustCor’s 
      website as the VP of TrustCor’s CA operations and the Director of 
      Operations for MsgSafe. [2]
      - 
      
      MsgSafe relies upon TrustCor’s role as an SMIME CA for its operation. 
      [3]
      - 
      
      MsgSafe is highlighted prominently in TrustCor’s own benefit 
      statement of its inclusion in Mozilla’s Root Program. [4]
      - 
      
      An early, unobfuscated version of the malware SDK produced by 
      Measurement Systems was included in TrustCor’s MsgSafe beta Android 
      application. [5]
      - 
   
   Measurement Systems and TrustCor have in the past had shared corporate 
   officers, operational control and technical integrations:
   - 
      
      Measurement Systems and TrustCor shared corporate officers until 2021 
      (or later). [6]
      - 
      
      Ian Abramowitz, was active in the operation of TrustCor as CFO and an 
      officer of the companies which owned both TrustCor and Measurement 
Systems. 
      [7]
      - 
      
      A developer hired by Trustcor had unobfuscated access to the source 
      code of Measurement System’s malware SDK and write access to the source 
      code of the MsgSafe application and hosting environment. [8]
      - 
   
   There is no evidence of TrustCor mis-issuing TLS or SMIME certificates.
   

There are suggestions of additional links between the companies whose 
factual basis has neither been fully substantiated nor refuted. For 
example, Ryan Abramowitz was previously the  CEO of both TrustCor and 
Measurement Systems. Ryan’s LinkedIn profile 
<https://www.linkedin.com/in/ryanabramowitz/details/experience/> previously 
listed: “Co-Founder / Digital Strategist TrustCor Systems · Jun 2013 - Dec 
2016. And D&B 
<https://www.dnb.com/business-directory/company-profiles.measurement_systems_s_de_rl.fe1d33ee8c1ff9a19bcc9c5b877cb483.html>
 
(a reputable business records company) shows Ryan as CEO of Measurement 
Systems.

Certificate Authorities have highly trusted roles in the internet ecosystem 
and it is unacceptable for a CA to be closely tied, through ownership and 
operation, to a company engaged in the distribution of malware. Trustcor’s 
responses via their Vice President of CA operations further substantiates 
the factual basis for Mozilla’s concerns. 

In line with our policies, Mozilla weighs the risks and benefits to 
end-user security when deciding whether a CA should be a member of our Root 
Program. Ordinarily, Mozilla would not directly evaluate the benefit of the 
CA owner’s other products when considering whether a CA should be a member 
of our Root Program. However, Trustcor’s quantifying value statement 
<https://04815712939683618271.googlegroups.com/attach/5f0bb22670488/TC_CA-Quantifying_Value_Statement.pdf?part=0.0.1.1&view=1&view=1&vt=ANaJVrG2BuuvwDdec09YHxygEuvjnuyYmLHHoNV8LQVTpx7JtolgguYv4uhr8cSHroAxjoeeyeEhqtCs6_fy3vTLxEnpcKNTuHv6PlqecBsUv1VXcgQx8XU>
 
rests heavily on the value of MsgSafe which has suffered from a number of 
problematic behaviors [9] that undermine the value proposition of MsgSafe, 
and therefore undermine the purported benefits for the TrustCor CA to be a 
member of our Root Program. 

Our assessment is that the concerns about TrustCor have been substantiated 
and the risks of TrustCor’s continued membership in Mozilla’s Root Program 
outweighs the benefits to end users. 

In line with our earlier communication 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/WJXUELicBQAJ>,
 
we intend to take the following actions:

   1. 
   
   Set “Distrust for TLS After Date” and “Distrust for S/MIME After Date” 
   to November 30, 2022, for the 3 TrustCor root certificates (TrustCor 
   RootCert CA-1, TrustCor ECA-1, TrustCor RootCert CA-2) that are currently 
   included in Mozilla’s root store.
   2. 
   
   Remove those root certificates from Mozilla’s root store after the 
   existing end-entity TLS certificates have expired.
   

If evidence is found that the CA has mis-used certificates or the CA 
backdates certificates to bypass the distrust-after settings, then we will 
remove the root certificates from Mozilla’s root store in an expedited 
timeline, without waiting for the end-entity TLS certificates to expire.

Mozilla will not accept cross-signing of the existing TrustCor root 
certificates by other root CA Operators in Mozilla’s root store. If 
TrustCor chooses to become a subordinate CA of another root CA Operator in 
Mozilla’s root store, then all domain and email address ownership 
verification and certificate issuance must be performed on the systems 
operated by the root CA Operator. I.e. The domain and email address 
ownership verification and certificate issuance must not be performed on 
systems operated by the TrustCor CA.

Mozilla would like to thank the researchers who brought this to our and the 
community’s attention, as well as the contributions from other members of 
the community.  

Thanks,

Kathleen

References:

[1] As reported in the Wall Street Journal, April 2022: 
https://archive.ph/AuNOy.

[2] Rachel McPherson is listed as the Vice President of Operations, having 
“access-to and control-over the CA and CA Business Operations” in a company 
document submitted privately by Rachel to Mozilla. Press releases on 
TrustCor’s website list Rachel McPherson as MsgSafe.io’s Director of 
Operations, e.g. 
https://web.archive.org/web/20221108224150/https://trustcor.com/news/02052016.php
.

[3] Rachel McPherson’s response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/iARnIrvwBQAJ>
 
to this thread on the 18th November 2022 states “MsgSafe.io 
<http://msgsafe.io>

integrates with TrustCor’s S/MIME certificate API for issuance of S/MIME 
certificates”. Further, TrustCor’s quantifying value statement 
<https://04815712939683618271.googlegroups.com/attach/5f0bb22670488/TC_CA-Quantifying_Value_Statement.pdf?part=0.0.1.1&view=1&view=1&vt=ANaJVrFIg25sIA5Zy1h9H20_FgvDgmM1Jz9W9cb8a4u3js8lVGuZVchTiqGqEomvLlEiAHyoml1ZqTTXO4S2wc5CdFSpDrUNKVfeo_IoYWBLzFAuhsXw8e8>
 
highlights that “While that might be achievable through partnership, as has 
been the case historically with S/MIME, business challenges and economics 
hinder widespread adoption which makes our continued root program 
membership absolutely critical.”

  

[4] TrustCor’s quantifying value statement 
<https://04815712939683618271.googlegroups.com/attach/5f0bb22670488/TC_CA-Quantifying_Value_Statement.pdf?part=0.0.1.1&view=1&view=1&vt=ANaJVrFIg25sIA5Zy1h9H20_FgvDgmM1Jz9W9cb8a4u3js8lVGuZVchTiqGqEomvLlEiAHyoml1ZqTTXO4S2wc5CdFSpDrUNKVfeo_IoYWBLzFAuhsXw8e8>,
 
under the heading “What Kind of Benefits can Your CA provide to Mozilla?”. 

[5] Technical analysis (1 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/u4KLEA6YBQAJ>,
 
2 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/6uYLVgWaBgAJ>)
 
produced by Serge Egelman. The inclusion of the malware was acknowledged in 
Rachel McPherson’s initial response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/iARnIrvwBQAJ>
 
and follow up responses 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/Q5GAYoTSBgAJ>
 
as well as providing further details on how it came to be included. 

 

[6] The identical corporate officers were acknowledged in Rachel 
McPherson’s initial response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/iARnIrvwBQAJ>
 
and confirmed in a company document submitted privately by Rachel to 
Mozilla.

 

[7] Ian Abramowitz is described as the CFO of TrustCor on their website 
<https://web.archive.org/web/20221108223409/https://trustcor.com/leadership> 
and Rachel McPherson’s initial response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/iARnIrvwBQAJ>
 
notes “They are strictly passive investors, with the exception of Ian 
Abramowitz”. In a company document submitted privately by Rachel to 
Mozilla, Ian Abramowitz signs an agreement with TrustCor on behalf of both 
CHIVALRIC HOLDING COMPANY LLC and FRIGATE BAY HOLDINGS LLC.      

[8] See [5] and Rachel McPherson’s response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/Q5GAYoTSBgAJ>
 
on 21st November 2022, referencing findings from their software revision 
control system and their forensic investigation of the an1.msgsafe.io 
hostname and saved VM image. 

[9]  Including, but not limited to: 1) the malware SDK produced by 
Measurement Systems was included in MsgSafe’s beta Android application. [5] 
2) For a period of time, user data was transmitted from MsgSafe’s beta 
Android application to a server operated by Trustcor, before being 
forwarded on to a third party. [10] 3) MsgSafe’s web application transmits 
user messages to MsgSafe’s servers in plaintext, even though MsgSafe is 
advertised as offering end to end encryption. [11]

[10] Rachel McPherson’s response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/Q5GAYoTSBgAJ>
 
on 21st November 2022, referencing TrustCor’s forensic investigation of the 
an1.msgsafe.io hostname and saved VM image.  

[11] End to end encryption is widely understood to mean that only the 
sender and receiver of a communication should be able to read or modify the 
messages, excluding access by third parties which operate servers or other 
intermediary network services. MsgSafe’s website 
<https://web.archive.org/web/20221130011310/https://www.msgsafe.io/> 
highlights the provision of end to end encryption, including the statement 
“MsgSafe.io cannot read your email.”. Technical investigations by members 
of the community (1 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/etbBho-VBQAJ>,
 
2 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/09ppQcZnCgAJ>)
 
confirm that in fact the webmail client transmits purportedly encrypted 
messages in plaintext to the server and that the server is able to recover 
the plaintext of those messages without the user’s password. Rachel 
McPherson’s initial response 
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/oxX69KFvsm4/m/iARnIrvwBQAJ>
 
describes this behavior as intentional, noting: “As the MsgSafe website 
explains, our team has found that implementing the key material and 
encryption/decryption processing on the server provides security without 
the additional processing requirement on the client”.   

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