Gervase Markham wrote:
> All comments welcomed. Ideally, I would be able to give any feedback to
> the editor before November 19th, after which there may be another vote
> on adopting the updated specification. If you have any questions about
> the process or the CABF, please ask.

Ok, I finally completed a review of the draft. A lot of it is beyond my
area of expertise, but I do have some concerns and questions regarding
the current draft.

* I don't actually see why individuals would need EV certificates, at
least during the first round. The way I see it EV certificates would be
mostly needed for banking and business, and most of that is AFAIK
conducted by actual companies and not individuals directly.

p. 10: Excluded purposes
* Has there been any thought about supporting any of the exluded
purposes? What if EV certificates would only be available for entities
who had already maintained a web presence at the same address for at
least a year? Auditors would then have some history to base an
investigation on. I do realize this would raise costs significantly, and
it could easily get into grey area... (I noticed that later on in the
verification requirements p. 26 there are some checks to make sure the
applicant is an established business with special steps to take if they
are under 3 years old. I like this, but I'd actually like it if there
was a requirement of at least one year prior web existence at that address.)

p. 11: Warranties
* What are the reasonable steps? Were they all described later in the doc?

p. 15: Domain name
* Would it be possible to go with dNSName only?
* If both commonName and dNSName are present, how is this situation handled?
* Wildcards are not allowed, but are multiple dNSNames allowed?

p. 17: validity period
* Where does 27 months come from?
* The documents listed all have 1 year expiration, so how is 27 months
even possible?

p. 21: reporting
* There doesn't actually seem to be much incentive for the applicant to
report if they have to pay for the new certificate as well. You could
make it so that the CA would give a free corrected certificate for the
remainder of the old one, or you could have the renewal process check if
the old information is correct and if not, refuse to supply a new EV
certificate until a year later. I am in favor of the first as the latter
leaves a window of unsafe/inaccurate information.

p. 26: verifying private registration
* I think it needs to be MUST to contact the applicant even in the case
of private registration to confirm the identity of the applicant. The CA
MUST then store this information privately at least for the duration of
the certificate validity time. Obviously, this information MUST NOT be
sold or given away except to comply with a subpoena or similar legal act.

p. 27: Mixed character set
* This leaves me a bit uneasy feeling. Are there no standards for mixed
charset domain names? Must we rely on domain registrar's judgement?
Could there be any algorithms to compare these to other High Risk domain
names?

p. 49: CA liability
* (1) I find it bizarre that the draft allows a CA to limit its
liabilities if it has not followed the EV guidelines. Why is this here?
* (2) I like this, it puts an incentive for the browsers and other
software to actually enable CRL/OCSP support by default.

p. 56: minimum crypto
* I find it depressing that the minimums allowed are so weak until 2010.
Any way to bring this deadline earlier, say 2008?

-- 
  Heikki Toivonen
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