On 12/23/2008 07:09 AM, Frank Hecker:
There are two general reasons for pulling a root, to address a clear and
present danger to Mozilla users, and to punish a CA and deter others. My
concern right now is with the former. I see at least three issues in
relation to that:

1. Issuance of further non-validated certs by this reseller. Comodo
seems to have addressed this by suspending the reseller's ability to get
certs issued. (I can testify that this is the case, as I tried to
duplicate Eddy's feat earlier today and got my uploaded CSR rejected.)

As long as this site keeps operating, our customers are still being let to believe that they have to renew their certificate with them. This is only a reminder about how it started at all. CAs and their customers are still taking damage from the previously sent messages.


2. Potential problems with certs already sold through this reseller.
Comodo should investigate this and take action if needed. (This need not
necessarily require revoking all certificates associated with the
reseller; for example, the existing certs and their associated domains
could be re-validated, the registered domain owners could be notified of
the potential for bogus certs floating around, etc.)

You shouldn't notify the subscribers or domain name owners, but the relying parties. How to do that is up to you and Comodo I guess.

Comodo not only shouldn't just investigate and take action, Comodo needs to report publicly about their findings and full report about the actions taken. This isn't a suggestion of resolution about this incident, it's the transparency I expect from them at this hour.

Pulling a Comodo root will knock out Firefox, etc., access to thousands
of SSL sites, maybe tens of thousands.

I'm not advocating removing their root, however we must assess the risk which is potentially caused to the relying parties. There may be thousands of sites which received certificates without validating them.

Given the disruption that would
cause, the final decision on this IMO should be made in conjunction with
the Firefox security folks.

Disabling the trust bits of "AddTrust External CA Root" could be a temporary measure to prevent damage to relying parties until Mozilla receives full report and disclosure from Comodo about its resellers and conclusion of their investigation.

Additionally instead of just yanking a root as a deterrent and punishment, as you mentioned above, I'd prefer to receive a commitment from Comodo to address other issues noted during the last discussion - mainly those listed in the "Problematic Practices" document. Considering that OCSP in Firefox is set to soft-fail, an issue with their OCSP server could still circumvent bogus sites for potentially the next five years. A full review of their current status in NSS and their practices might be advocated too.

--
Regards

Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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