On Mon, Jun 10, 2024 at 7:28 PM Ben Wilson <[email protected]> wrote:

> Preferably here, but if the requests for clarification are structured in
> markdown in Bugzilla as replies to Comment 1
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1901270#c1>, then that
> would be acceptable, too. Otherwise, general comments and critiques should
> be made here.
>

Sorry, I meant: will Mozilla’s requests for clarification from Entrust be
posted to mdsp or the bug or etc.?

For efficiency, it is requested that comments and requests for
> clarification be collected into as few emails/posts as possible and not be
> posted in piecemeal fashion.
>

Touché…

Mike

Thanks,
>
> Ben
>
>
>>
>> Does this mean that Mozilla feels that the action items listed in that
>> bug are sufficiently detailed and concrete that they are appropriate as
>> steps for Entrust to take at this point?
>>
>> Mike
>>
>> On Mon, Jun 10, 2024 at 4:16 PM 'Ben Wilson' via
>> [email protected] <[email protected]> wrote:
>>
>>> All,
>>>
>>> This is to acknowledge that we have received Entrust's June 7 Report
>>> regarding its non-compliance issues and associated remediation plans.
>>> Mozilla will thoroughly review the report and provide comments, requests
>>> for clarifications, and verify that the requested items have been and will
>>> be addressed in accordance with the request for the Report and the Action
>>> Items listed in Bugzilla Bug #1901270
>>> <https://bugzilla.mozilla.org/show_bug.cgi?id=1901270>.
>>>
>>> Our review process will include:
>>>
>>>    - Assessing the root cause analyses and improvement plans.
>>>    - Ensuring that all issues listed in the report and related Bugzilla
>>>    discussions have been addressed.
>>>    - Verifying that the remediation plans align with the expectations
>>>    and requirements set forth by the Mozilla Root Store Policy and the
>>>    CA/Browser Forum TLS Baseline Requirements.
>>>    - Requesting any necessary clarifications or additional information
>>>    to ensure comprehensive compliance and future prevention of similar
>>>    incidents.
>>>
>>> We will follow up with specific comments and requests for clarifications
>>> as needed.
>>>
>>> Thank you for your attention to these important matters.
>>>
>>> Ben
>>>
>>>
>>> On Fri, Jun 7, 2024 at 1:53 PM 'Bruce Morton' via
>>> [email protected] <[email protected]> wrote:
>>>
>>>> Please respond to comments you may have on our report or action items
>>>> here.  We will track our progress against the action items list in Bugzilla
>>>> under bug 1901270.
>>>>
>>>> On Friday, June 7, 2024 at 12:51:48 PM UTC-4 Ben Wilson wrote:
>>>>
>>>>> All,
>>>>> I have created Bugzilla Bug#1901270
>>>>> <https://bugzilla.mozilla.org/show_bug.cgi?id=1901270> as an Entrust
>>>>> "meta" bug for gathering all action items that will be included in their
>>>>> report.
>>>>> Please don't comment yet in that bug until Entrust has submitted its
>>>>> report and populated the Bugzilla bug with their action items.
>>>>> Thanks,
>>>>> Ben
>>>>>
>>>>> On Friday, June 7, 2024 at 4:41:03 AM UTC-6 [email protected] wrote:
>>>>>
>>>>>> As an advanced warning to Entrust on supplying the report please keep
>>>>>> in mind that MDSP has a moderation queue for new members. If the report 
>>>>>> is
>>>>>> to be sent to the mailing list today, then please make sure to use an
>>>>>> account that has been pre-approved, or otherwise submit it early enough
>>>>>> that a moderator can approve it to arrive on-time.
>>>>>>
>>>>>> On Wednesday, May 15, 2024 at 4:06:49 PM UTC+1 Amir Omidi (aaomidi)
>>>>>> wrote:
>>>>>>
>>>>>>> I wanted to also add that I'd like Entrust to address why they don't
>>>>>>> stop certificate issuances when they find out they're misissuing
>>>>>>> certificates?
>>>>>>>
>>>>>>> As part of my series on Entrust
>>>>>>> <https://webpki.substack.com/t/entrust-considered-harmful>. In Part
>>>>>>> 2 <https://webpki.substack.com/p/entrust-considered-harmful-part-2>
>>>>>>> I found a concerning issue from Entrust that went unnoticed at the time,
>>>>>>> which shows a pattern of gross-negligence when it comes to incident
>>>>>>> response: Entrust: SHA-256 hash algorithm used with ECC P-384 key
>>>>>>> <https://bugzilla.mozilla.org/show_bug.cgi?id=1648472>
>>>>>>>
>>>>>>> In this incident, Entrust discovers that they're misissuing
>>>>>>> certificates on 2020-06-17. Despite finding out about this incident, 
>>>>>>> they
>>>>>>> continue to misissue certificates all the way till 2020-06-24:
>>>>>>> https://crt.sh/?id=2998515551&opt=zlint
>>>>>>>
>>>>>>> There have been a couple of examples of Entrust making this decision
>>>>>>> in the past, such as: Entrust: Printable String Constraint Failure
>>>>>>> <https://bugzilla.mozilla.org/show_bug.cgi?id=1635096>. Similar to
>>>>>>> the previous incident, they did not disable issuance on their systems 
>>>>>>> that
>>>>>>> was capable of misissuing certificates (emphasis mine):
>>>>>>> >      Whether your CA has stopped, or has not yet stopped, issuing
>>>>>>> certificates with the problem. A statement that you have will be 
>>>>>>> considered
>>>>>>> a pledge to the community; a statement that you have not requires an
>>>>>>> explanation.
>>>>>>>
>>>>>>>         The CA software has a bug which encodes quotation marks in
>>>>>>> the organization field using PrintableString instead of UTF8String. 
>>>>>>> *This
>>>>>>> software has not been fixed at this time.*
>>>>>>>
>>>>>>> And more recently, we saw this behavior in the start of this saga: 
>>>>>>> Entrust:
>>>>>>> EV TLS Certificate cPSuri missing
>>>>>>> <https://bugzilla.mozilla.org/show_bug.cgi?id=1883843#c4>
>>>>>>>
>>>>>>> On Saturday, May 11, 2024 at 6:37:52 PM UTC-4 Wayne wrote:
>>>>>>>
>>>>>>>> I can't speak for everyone but in an issue of public trust asking
>>>>>>>> for private feedback and concerns is not helping matters.
>>>>>>>>
>>>>>>>> One of the prevalent topics that have came up in these issues is
>>>>>>>> shorter certificate lifespans, certificate automation and how Entrust 
>>>>>>>> are
>>>>>>>> working very hard with their customers. I'm very curious if Entrust can
>>>>>>>> quantify this in any way?
>>>>>>>>
>>>>>>>> Taking a step back and just looking at their public statements
>>>>>>>> regarding lifespans, automation and ACME should give us an idea of 
>>>>>>>> their
>>>>>>>> internal viewpoint and how this topic is presented to customers. 
>>>>>>>> Outside of
>>>>>>>> the first issue I won't be quoting bugzilla, it's there solely to 
>>>>>>>> provide
>>>>>>>> context as I can't see an earlier point that automation was promised.
>>>>>>>>
>>>>>>>> Let's dive in, sources all provided if there are any questions
>>>>>>>> about the rough transcript or context.
>>>>>>>>
>>>>>>>> *1: 2023-03-27: Entrust: Delayed Revocation for EV TLS Certificate
>>>>>>>> incorrect jurisdiction*
>>>>>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1804753#c8
>>>>>>>> *---*
>>>>>>>> Late revocations are base primarily by Subscribers which have not
>>>>>>>> implemented automation. We have increased our efforts to extend
>>>>>>>> implementation of ACME. We are also considering implementing the ACME
>>>>>>>> Renewal Information (ARI) Extension, which allow the certificate to be
>>>>>>>> automatically renewed before the revocation date.
>>>>>>>>
>>>>>>>> In the shorter term, we will provide Subscribers with automated
>>>>>>>> reminders on the revocation date for miss-issued certificates. We will 
>>>>>>>> plan
>>>>>>>> to allow short extensions, based on the severity of the miss-issuance.
>>>>>>>> *---*
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>> *2: 2023-04-21: Google’s 90 day proposal for TLS certificates*
>>>>>>>>
>>>>>>>> https://www.entrust.com/blog/2023/04/googles-90-day-proposal-for-tls-certificates/
>>>>>>>> *---*
>>>>>>>> Even if CAs and other browsers don’t share Google’s objectives,
>>>>>>>> there is a chance that Google could unilaterally make this change in 
>>>>>>>> its
>>>>>>>> root program and force the entire industry in this direction in a time 
>>>>>>>> of
>>>>>>>> their choosing. We hope that browsers will not make this decision
>>>>>>>> unilaterally, but instead allow the decision to be made with broad 
>>>>>>>> industry
>>>>>>>> and website owner consensus.
>>>>>>>>
>>>>>>>> Another issue is that Google has presented no public research or
>>>>>>>> factual data showing that such a change to the ecosystem is necessary 
>>>>>>>> or
>>>>>>>> useful in many use cases. We believe there will be much discussion 
>>>>>>>> before a
>>>>>>>> 90-day ballot will pass at the CABF as several CAs have indicated that 
>>>>>>>> a
>>>>>>>> requirement for 90-day certificates might have far-reaching 
>>>>>>>> implications.
>>>>>>>> There have also been several EU governmental bodies concerned over the
>>>>>>>> market and competitive implications of Google’s proposal and the 
>>>>>>>> impact on
>>>>>>>> eIDAS Qualified Website Authentication Certificate objectives, which 
>>>>>>>> are
>>>>>>>> now being reasserted in the EU’s update of its eIDAS legislation.
>>>>>>>>
>>>>>>>> Entrust does not believe that a maximum 90-day limit for TLS
>>>>>>>> certificate lifetimes is the only method to drive automation and the
>>>>>>>> deployment of ACME. Additionally, Entrust doesn’t believe that ACME is 
>>>>>>>> the
>>>>>>>> only method for automation, or that it would be accepted by some of the
>>>>>>>> most complex subscriber secure server deployments. Rather, we believe
>>>>>>>> subscribers should be encouraged to deploy automation, but do not need 
>>>>>>>> to
>>>>>>>> be discouraged by the cost and complexity of certificates with 90-day
>>>>>>>> maximum validity.
>>>>>>>>
>>>>>>>> While Entrust is not currently in favor of a mandatory 90-day
>>>>>>>> certificate limit, we have no objection to 90-day certificates if that 
>>>>>>>> is
>>>>>>>> what a website wants to use. We are always working to improve or 
>>>>>>>> extend its
>>>>>>>> validation, issuance, and management processes, including greater use 
>>>>>>>> of
>>>>>>>> automation through integrations with certificate lifecycle management 
>>>>>>>> (CLM)
>>>>>>>> solutions such as Entrust Certificate Hub, AppViewX, Venafi, and
>>>>>>>> ServiceNow, as well as automation through ACME v2, CMP, SCEP, and 
>>>>>>>> other new
>>>>>>>> methods.
>>>>>>>>
>>>>>>>> We understand that this Google proposal may be causing our
>>>>>>>> customers considerable concern. In accordance with Google’s 
>>>>>>>> instructions on
>>>>>>>> its Chrome Root Program Policy, we encourage customers to direct any
>>>>>>>> questions or input regarding the Google proposal to
>>>>>>>> [email protected]; please feel free to share a copy with us
>>>>>>>> at [email protected].
>>>>>>>> *---*
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>> *3: 2023-07-26: Entrust Cybersecurity Institute Explains: 90-day
>>>>>>>> TLS/SSL Certificate Lifecycle*
>>>>>>>> https://www.youtube.com/watch?v=GcKunPD5SRw
>>>>>>>> *---*
>>>>>>>> 0:41-1:48
>>>>>>>> Today we're using certificates that are generally valid for about a
>>>>>>>> year. Technically, according to the requirements, we can go to 398 
>>>>>>>> days to
>>>>>>>> give you a bit of room so that you can have one day of the year at 
>>>>>>>> which
>>>>>>>> you renew your certificates. That is something that is easy to 
>>>>>>>> remember,
>>>>>>>> scheduling your agenda as a yearly renewal of those certificates when 
>>>>>>>> they
>>>>>>>> need to happen.
>>>>>>>>
>>>>>>>> When they're moving to shorter-lived certificates, such as the
>>>>>>>> proposed 90 days, this means that you need to do this now four times a 
>>>>>>>> year
>>>>>>>> in a window of 90 days.
>>>>>>>>
>>>>>>>> Moving to 90-day certificates means that you're practically going
>>>>>>>> to renew your certificates probably every 60 days. Meaning that in the 
>>>>>>>> end,
>>>>>>>> you have to replace your certificates four to six times a year, 
>>>>>>>> depending
>>>>>>>> on what window you allow to renew that certificate.
>>>>>>>>
>>>>>>>> 90-day certificates will have a few benefits. So one is that they
>>>>>>>> will drive automation.
>>>>>>>>
>>>>>>>>
>>>>>>>> 2:51-3:30
>>>>>>>> That doesn't [mean to] say that there's no problems and that 90-day
>>>>>>>> certificates are actually going to solve this. Crypto agility is 
>>>>>>>> important,
>>>>>>>> but that means more than just automating your certificate lifecycle.
>>>>>>>>
>>>>>>>> For example, if the CA would give you an indication through the
>>>>>>>> automated system that your certificate must be replaced, how does 
>>>>>>>> currently
>>>>>>>> the CA know that your system is capable of running a certain algorithm?
>>>>>>>> Have you updated your libraries?
>>>>>>>>
>>>>>>>> So we still have a long step ahead of us really to make that crypto
>>>>>>>> agility a reality.
>>>>>>>>
>>>>>>>> 4:41-end
>>>>>>>>
>>>>>>>> We're working with the Internet Engineering Task Force, where
>>>>>>>> Anthos(?) created a proposal for a sort of auto-discovery based on the 
>>>>>>>> most
>>>>>>>> used automation, the ACME Auto Certificate Management Environment.
>>>>>>>>
>>>>>>>> And that would help our customers actually to simplify this
>>>>>>>> mechanism of renewing certificates in different platforms with 
>>>>>>>> different
>>>>>>>> systems, without having to reconfigure every individual system to work 
>>>>>>>> with
>>>>>>>> the certificate authority and the type of certificates they're dealing
>>>>>>>> with. Together with[sic] very important is one of the risks of 
>>>>>>>> automation,
>>>>>>>> is that you're not doing it as a human.
>>>>>>>>
>>>>>>>> If you do a process, if you follow a step-by-step process that is
>>>>>>>> defined and tested, then you know the outcome, because you're 
>>>>>>>> following the
>>>>>>>> steps. But in automation, something might go wrong. And how do you 
>>>>>>>> know?
>>>>>>>> You need to make sure that systems are notifying you as someone is 
>>>>>>>> watching
>>>>>>>> the notifications.
>>>>>>>>
>>>>>>>> That's also why in this similar proposal, we've included the
>>>>>>>> mechanism of backup configuration. So if one process would fail, there 
>>>>>>>> is
>>>>>>>> another process that can be followed. But other things are still in
>>>>>>>> development. And we will see how that turns out. But the ecosystem 
>>>>>>>> seems to
>>>>>>>> be supporting it.
>>>>>>>> *---*
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>> *4: 2023-07-26: Entrust Cybersecurity Institute Explains: Zero
>>>>>>>> Trust and TLS/SSL Certificate Management*
>>>>>>>> https://www.youtube.com/watch?v=nd0QCvu2F_E
>>>>>>>> *---*
>>>>>>>> 1:20-2:18
>>>>>>>>
>>>>>>>> Well, first I would say we need to adopt automation. But then at
>>>>>>>> the same point, I would point them at the risk of automation. Where
>>>>>>>> processes by humans are easily manageable and can have multiple steps 
>>>>>>>> to
>>>>>>>> ensure they flow correctly. Without automation, this could be more
>>>>>>>> challenging.
>>>>>>>>
>>>>>>>> For example, if you implement automation for your TLS certificates,
>>>>>>>> this means that you need to have a credential for your certificate
>>>>>>>> authority. You need to also have a credential, for example, for your 
>>>>>>>> domain
>>>>>>>> name provider, your DNS system. And that's all needed to prove domain
>>>>>>>> control and to make sure that a certificate with the right identity is
>>>>>>>> issued for your endpoints.
>>>>>>>>
>>>>>>>> But what if these credentials get compromised? Look at the DNS
>>>>>>>> system.
>>>>>>>> *---*
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>> *5: 2023-08-14: Short-lived Certificates finally approved*
>>>>>>>>
>>>>>>>> https://www.entrust.com/blog/2023/08/short-lived-certificates-finally-approved/
>>>>>>>> *---*
>>>>>>>> After more than 10 years, short-lived TLS certificates are finally
>>>>>>>> permitted by the browsers based on CA/Browser Forum ballot SC-063. Gerv
>>>>>>>> Markham started a short-lived certs discussion in 2014, where he 
>>>>>>>> advised he
>>>>>>>> was reviewing the 2012 CA/Browser Forum discussion on the topic. He 
>>>>>>>> advised
>>>>>>>> that short-lived certificates was a plank of the Mozilla revocation
>>>>>>>> strategy. There was also a paper prepared in 2012 called Towards
>>>>>>>> Short-Lived Certificates. The paper stated OCSP is as good as dead, so 
>>>>>>>> the
>>>>>>>> CAs should issue certificates with a very short lifetime. I suppose no 
>>>>>>>> one
>>>>>>>> thought it would take so much time.
>>>>>>>>
>>>>>>>> Short-lived certificates are designed to help address a certificate
>>>>>>>> revocation issue. Back in 2012, Adam Langley discussed the seat-belt 
>>>>>>>> issue,
>>>>>>>> where it works fine, but snaps when you crash. This was based on the 
>>>>>>>> fact
>>>>>>>> the browser implements soft-fail revocation checks where the CRL or 
>>>>>>>> OCSP
>>>>>>>> response is ignored.
>>>>>>>> *---*
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>> *6: 2024-03-26: The Path to 90-Day Certificate Validity: Challenges
>>>>>>>> Facing Organizations*
>>>>>>>>
>>>>>>>> https://www.entrust.com/blog/2024/03/the-path-to-90-day-certificate-validity-challenges-facing-organizations/
>>>>>>>> *---*
>>>>>>>> Certificate lifespan is getting shorter
>>>>>>>>
>>>>>>>> Over the years the cybersecurity industry has undergone notable
>>>>>>>> transformations requiring organizations to implement new best-practice
>>>>>>>> standards, often at a short notice.
>>>>>>>>
>>>>>>>> In 2020, Apple unilaterally opted for shorter TLS certificate
>>>>>>>> durations, reducing them from three years to 398 days, thereby 
>>>>>>>> increasing
>>>>>>>> the burden on certificate management. Subsequently, Apple introduced
>>>>>>>> shorter lifespans for S/MIME certificates at the start of 2022. In the 
>>>>>>>> past
>>>>>>>> year, both code signing and S/MIME users faced additional alterations,
>>>>>>>> while Google proposed transitioning to 90-day certificates, a subject 
>>>>>>>> we
>>>>>>>> have explored in our latest webinar. Anticipating further changes,
>>>>>>>> particularly with the rise of artificial intelligence (AI) and the 
>>>>>>>> looming
>>>>>>>> risk of post-quantum (PQ) computing, organizations must enhance their
>>>>>>>> agility.
>>>>>>>>
>>>>>>>> Today, TLS/SSL certificates are typically valid for about a year,
>>>>>>>> according to the Certification Authority Browser (CA/B) Forum 
>>>>>>>> requirements.
>>>>>>>> This yearly renewal cycle is convenient for organizations to manage and
>>>>>>>> schedule. However, transitioning to shorter-lived certificates, like 
>>>>>>>> the
>>>>>>>> proposed 90-day validity period, will require more frequent renewal
>>>>>>>> efforts. With 90-day validity, organizations will need to renew
>>>>>>>> certificates four times every 12 months within that timeframe. In 
>>>>>>>> practice,
>>>>>>>> due to the need for buffer time, certificates may need to be renewed 
>>>>>>>> every
>>>>>>>> 60 days. Ultimately, this change could lead to replacing certificates 
>>>>>>>> more
>>>>>>>> than six times every 12 months, depending on the renewal window chosen.
>>>>>>>> *---*
>>>>>>>>
>>>>>>>> Apologies that some of those got long, I wanted to preserve as much
>>>>>>>> context as possible given how little material we have to work with.
>>>>>>>>
>>>>>>>> I sincerely ask anyone if they can find any further communication
>>>>>>>> on these topics by Entrust. Their helpdesk has tutorials on specific
>>>>>>>> software setups, but I'm not seeing any actual push for their 
>>>>>>>> subscribers
>>>>>>>> to do anything.
>>>>>>>>
>>>>>>>> It would be very beneficial for Entrust to provide us with any
>>>>>>>> information on what they've been communicating to their customers to
>>>>>>>> promote shorter certificate lifespans and automation.
>>>>>>>>
>>>>>>>> - Wayne
>>>>>>>>
>>>>>>>> On Saturday, May 11, 2024 at 8:04:24 PM UTC+1 Chris Bailey wrote:
>>>>>>>>
>>>>>>>>> To Ben Wilson and the Mozilla Community:
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> I want to acknowledge your letter and the input from you and the
>>>>>>>>> community. We agree that we have go-forward opportunities to improve.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> To that end, I want to confirm our intent to provide a full
>>>>>>>>> written response to you and the community prior to June 7. Until then,
>>>>>>>>> please contact me directly with additional questions or feedback.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Sincerely,
>>>>>>>>>
>>>>>>>>> Chris Bailey
>>>>>>>>>
>>>>>>>>> VP-Digital Certificates
>>>>>>>>>
>>>>>>>>> Entrust
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> *From: *'Ben Wilson' via [email protected] <
>>>>>>>>> [email protected]>
>>>>>>>>> *Date: *Tuesday, May 7, 2024 at 10:59 AM
>>>>>>>>> *To: *[email protected] <[email protected]>
>>>>>>>>> *Subject: *[EXTERNAL] Recent Entrust Compliance Incidents
>>>>>>>>>
>>>>>>>>> Dear Mozilla Community, Over the past couple of months, a
>>>>>>>>> substantial number of compliance incidents have arisen in relation to
>>>>>>>>> Entrust. We have summarized these recent incidents in a dedicated wiki
>>>>>>>>> page: https: //wiki. mozilla. org/CA/Entrust_Issues.
>>>>>>>>>
>>>>>>>>> Dear Mozilla Community,
>>>>>>>>>
>>>>>>>>> Over the past couple of months, a substantial number of compliance
>>>>>>>>> incidents have arisen in relation to Entrust. We have summarized these
>>>>>>>>> recent incidents in a dedicated wiki page:
>>>>>>>>> https://wiki.mozilla.org/CA/Entrust_Issues
>>>>>>>>> <https://urldefense.com/v3/__https:/wiki.mozilla.org/CA/Entrust_Issues__;!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmM8uUFZ84$>.
>>>>>>>>> In brief, these incidents arose out of certificate mis-issuance due 
>>>>>>>>> to a
>>>>>>>>> misunderstanding of the EV Guidelines, followed by numerous mistakes 
>>>>>>>>> in
>>>>>>>>> incident handling (including a deliberate decision to continue
>>>>>>>>> mis-issuance), which have been compounded by a failure to remediate 
>>>>>>>>> the
>>>>>>>>> issues in a timely fashion in line with well-established norms and 
>>>>>>>>> root
>>>>>>>>> store requirements.
>>>>>>>>>
>>>>>>>>> Our preliminary assessment of these incidents is that while they
>>>>>>>>> were relatively minor initially, the poor incident response has
>>>>>>>>> substantially aggravated them and the progress towards full 
>>>>>>>>> remediation
>>>>>>>>> remains unacceptably slow. This is particularly disappointing in 
>>>>>>>>> light of
>>>>>>>>> previous incidents in 2020 (#1651481
>>>>>>>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1651481__;!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMYStPTzU$>
>>>>>>>>> and #1648472
>>>>>>>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1648472__;!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMQsOKu7I$>),
>>>>>>>>> which arose out of similar misunderstandings of the requirements, 
>>>>>>>>> similar
>>>>>>>>> poor decision-making in the initial response, and lengthy remediation
>>>>>>>>> periods that fell well below expectations. Entrust gave
>>>>>>>>> commitments
>>>>>>>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1651481*c17__;Iw!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMgQVGatQ$>
>>>>>>>>> in those bugs to address the root problems through process 
>>>>>>>>> improvements,
>>>>>>>>> and it is concerning to see so little improvement 4 years later.
>>>>>>>>>
>>>>>>>>> In light of these recent incidents, we are requesting that Entrust
>>>>>>>>> produce a detailed report of them. This report should cover in detail:
>>>>>>>>>
>>>>>>>>>    - The factors and root causes that lead to the initial
>>>>>>>>>    incidents, highlighting commonalities among the incidents and any 
>>>>>>>>> systemic
>>>>>>>>>    failures;
>>>>>>>>>    - Entrust’s initial incident handling and decision-making in
>>>>>>>>>    response to these incidents, including any internal policies or 
>>>>>>>>> protocols
>>>>>>>>>    used by Entrust to guide their response and an evaluation of 
>>>>>>>>> whether their
>>>>>>>>>    decisions and overall response complied with Entrust’s policies, 
>>>>>>>>> their
>>>>>>>>>    practice statement, and the requirements of the Mozilla Root 
>>>>>>>>> Program;
>>>>>>>>>    - A detailed timeline of the remediation process and an
>>>>>>>>>    apportionment of delays to root causes; and
>>>>>>>>>    - An evaluation of how these recent issues compare to the
>>>>>>>>>    historical issues referenced above and Entrust’s compliance with 
>>>>>>>>> its
>>>>>>>>>    previously stated commitments.
>>>>>>>>>
>>>>>>>>> Finally, Entrust’s report should include a detailed proposal on
>>>>>>>>> how it plans to address the root causes of these issues. In light of
>>>>>>>>> previous guarantees
>>>>>>>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1651481*c17__;Iw!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMgQVGatQ$>
>>>>>>>>> given by Entrust in 2020 to ensure speedy remediation in future 
>>>>>>>>> incidents,
>>>>>>>>> this proposal should include:
>>>>>>>>>
>>>>>>>>>    - Clear and concrete steps that Entrust proposes to take to
>>>>>>>>>    address the root causes of these incidents and delayed remediation;
>>>>>>>>>    - Measurable and objective criteria for Mozilla and the
>>>>>>>>>    community to evaluate Entrust’s progress in deploying these 
>>>>>>>>> solutions; and
>>>>>>>>>    - A timeline for which Entrust will commit to meeting these
>>>>>>>>>    criteria.
>>>>>>>>>
>>>>>>>>> We strongly recommend that Entrust go beyond their existing
>>>>>>>>> commitment
>>>>>>>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1886532*c0__;Iw!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmM8gYsLCM$>
>>>>>>>>> to offer systematic, automated solutions for effective remediation, 
>>>>>>>>> like
>>>>>>>>> ACME ARI and that it also include clear and measurable targets for the
>>>>>>>>> adoption of these tools by new and existing subscribers.
>>>>>>>>>
>>>>>>>>> This report should be submitted to Mozilla dev-security-policy
>>>>>>>>> mailing list for evaluation by the community and Mozilla, who will 
>>>>>>>>> weigh
>>>>>>>>> whether Entrust’s report presents a credible and effective path 
>>>>>>>>> towards
>>>>>>>>> re-establishing trust in Entrust’s operation. Submission should be no 
>>>>>>>>> later
>>>>>>>>> than June 7, 2024.
>>>>>>>>>
>>>>>>>>> We thank community members for their engagement on these issues
>>>>>>>>> and look forward to their feedback on Entrust’s report and proposed
>>>>>>>>> commitments.
>>>>>>>>>
>>>>>>>>>  Thanks,
>>>>>>>>>
>>>>>>>>> Ben Wilson
>>>>>>>>>
>>>>>>>>> Mozilla Root Program
>>>>>>>>>
>>>>>>>>> --
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>>>>>>>>> <https://urldefense.com/v3/__https:/groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/CA*2B1gtaYURqFzRqVmJdc7fBXE1mbGs25HpSkp5wZ0Xm*2BRG0YHCA*40mail.gmail.com?utm_medium=email&utm_source=footer__;JSUl!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmM525_4vY$>
>>>>>>>>> .
>>>>>>>>> *Any email and files/attachments transmitted with it are intended
>>>>>>>>> solely for the use of the individual or entity to whom they are 
>>>>>>>>> addressed.
>>>>>>>>> If this message has been sent to you in error, you must not copy,
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>>>>>>>>> Entrust immediately and delete the message from your system.*
>>>>>>>>>
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