Dear Andrew and all,

We understand your concerns.

We are evaluating and considering your suggestions.

Thanks,

Ben Wilson

Mozilla Root Program Manager
On Tuesday, June 11, 2024 at 4:58:02 PM UTC-6 [email protected] wrote:

> I have to echo the sentiments, and question what setting a notBefore date 
> weeks into the future signals to a non-compliant CA. If we're already in 
> agreement that trust is lost, what does this grace period provide if not 
> more room for either unintionally malicious, or actively malicious actions 
> even by a third party? Any actions that have caused a CA to get into this 
> trust state are doubtless continuing in the leadup to the final notBefore 
> day.
>
> Isn't this in effect a tacit agreement for a non-compliant CA to do what 
> they wish for the next few weeks, because ultimately what is going to 
> happen if they don't? What would be a root program's response is on the 
> issuance of a distrust statement a CA then quietly sells non-SCT 
> certificates for, say, interception purposes? It's a narrower window of 
> opportunity but I can see a CA who is looking to make one last grab for 
> cash on the way out abusing this system as it stands. I'm of the opinion 
> that we need to build these enforcement mechanisms defensively and presume 
> a malicious party if only for the security implications.
>
> I can see an argument for a few days for the CA to recognize they are no 
> longer trusted and to remove all documentation stating that their future 
> issuances would work in specific root chains. I just don't see the security 
> or integrity rationale in such a wide window, although I recognize that it 
> has previous precedent I'd echo my statements to those as well.
>
> - Wayne
>
> On Tuesday, June 11, 2024 at 10:55:29 PM UTC+1 Mike Shaver wrote:
>
>> I have to agree with Andrew. Continuing to trust this root and the 
>> integrity of "notBefore" on the certs it issues seems like it adds risk to 
>> Firefox and Thunderbird users without basically any value to the world. If 
>> those certificates have their key material leak, do we have any reason to 
>> believe that ECM will actually spring to life and help the subscribers? I 
>> cannot think of such a reason.
>>
>> IMO we should excise it cleanly, and let Mozilla's users deal with the 
>> fact that they can't access those handful of sites--if indeed they ever 
>> ever notice.
>>
>> Mike
>>
>>
>> On Tue, 11 Jun 2024 at 15:55, Andrew Ayer <[email protected]> wrote:
>>
>>> On Tue, 11 Jun 2024 13:11:16 -0400
>>> Andrew Ayer <[email protected]> wrote:
>>>
>>> > If we exclude ECM's own domains, this drops down to just 36 distinct
>>> > DNS names.
>>>
>>> Further analysis: of the 36 DNS names,
>>>
>>> 18 are serving a non-ECM certificate on port 443
>>> 9 are serving an ECM certificate on port 443
>>> 6 did not respond on port 443
>>> 3 are wildcard DNS names
>>>
>>> Regards,
>>> Andrew
>>>
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>>>
>>

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