On Wednesday 2006-11-01 22:54 +0000, Gervase Markham wrote:
> The guidelines have been developed via a very long and drawn-out 
> process, including several face-to-face meetings with competing 
> specifications from different groups of CAs over the past two years. 
> Eventually and quite recently, a Microsoft employee synthesised a 
> unified specification, which has now been made available for public 
> comment. The latest draft of this document can be found here:
> http://www.cabforum.org/EV_Certificate_Guidelines_-_Draft_10-2...pdf

After skimming some parts of the draft, my biggest concern here is
the tension between B.2.a.1 and B.2.c.3, and its implications on
when certificates would be revoked.

In particular, I think misrepresentation of identity within a Web
site that uses an EV cert must be grounds for revocation.  B.2.a.1
says that one of the primary purposes of a cert is to identify the
legal entity behind a Web site.  But I don't think the average
consumer knows the exact name of the legal entity running every
business they interact with.

For example, suppose a company is formed called "Washington Banking,
Inc.", and they apply for and obtain an EV cert under that name.
They then write a Web site that uses the name and logo of Washington
Mutual as part of a "phishing" attack.  What percentage of consumers
would know that the legal entities behind the bank they know as
Washington Mutual are (based on the contents of
http://www.wamu.com/personal/default.asp ) "Washington Mutual Bank",
"Washington Mutual, Inc.", and other legal entities, but not
"Washington Banking, Inc"?

It seems that given that preventing such an attack is excluded from
the purposes of EV certificates and would not (I think, although I
didn't follow all the pointers leading out of the revocation part of
the spec) lead to revocation of the certificate.  This seems like a
problem.

It seems like this spec overemphasizes the concept of "legal entity"
when the real problem here is misrepresentation of identity.  So
shouldn't misrepresentation of identity, within any Web site served
using an EV cert, be grounds for revocation of that cert?  In other
words, it seems to me that B.2.b.1 should be a primary purpose of EV
certificates, and B.2.a.1 should be secondary.


Also, what's the time scale of the average phishing attack?  Are the
revocation guarantees in the spec (G.26.a) actually useful, or will
the attack be mostly over by the time anything is usefully revoked?

> The Mozilla project as a whole needs to decide whether EV will make a 
> material difference to the reliability of information in certificates 
> and, if so, whether that warrants a different UI presentation for EV 
> certificates. It would also be good to have a more general discussion 
> about how we present security information to users.

Presumably the idea here is that we would have a process for
determining that root CAs on our list are also valid EV root CAs,
and mark them as such?  Would we need a policy for determining which
CAs should be so marked?  I'd think we should have a clear policy
for this, and for when we would *un*-mark a CA.  And I think we
should have that clearly defined before we start doing anything with
EV certificates, and make it clear in advance that if CAs do any of
the things that we said would make them be kicked out of our root CA
list, we'd actually do it.

-David

-- 
L. David Baron                                <URL: http://dbaron.org/ >
           Technical Lead, Layout & CSS, Mozilla Corporation

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