> On Apr 28, 2017, at 9:06 AM, Kirk Hall via Public <[email protected]> wrote:
>  
> 1.  It appears from various comments over time that your biggest concern 
> about re-use of prior validation data relates to method 3.2.2.4.6 – Agreed 
> Upon Change to Website.  Old method 6 required “Having the Applicant 
> demonstrate practical control over the FQDN by making an agreed-upon change 
> to information found on an online Web page identified by a uniform resource 
> identifier containing the FQDN”
>  
> New method 6 requires specified content be posted to a 
> "/.well‐known/pki‐validation" directory, which no CA has ever done (because 
> this path is brand new, and created for the updated version of this 
> validation method).  So prohibiting reuse of data collected under old method 
> 6 will necessarily require revalidation of ALL domains ever validated under 
> old method 6.  As I indicated on the CABF teleconference yesterday, this will 
> require some CAs (including Entrust) to manually review EVERY domain 
> validation we have done to determine which used old method 6, versus other 
> approved methods.  This would be a massive undertaking, and something CAs 
> won’t want to do unless there is a demonstrated security need.
>  
> Can you share with us the facts, data, evidence, etc. that leads you to 
> believe that the domain validations previously done under old method 6 pose a 
> significant security threat to users?  Any statistics to back this up?  I’m 
> not challenging you, I’m just asking you for data that supports what you want 
> us to do.  We are not aware of any instance where we used old method 6 and 
> later discovered that the domain should not have been authorized for the 
> customer.

Kirk,

I did some research on this back when we were working on ballot 169.  See 
https://cabforum.org/pipermail/public/2016-April/007504.html 
<https://cabforum.org/pipermail/public/2016-April/007504.html> and 
https://cabforum.org/pipermail/public/2016-April/007506.html 
<https://cabforum.org/pipermail/public/2016-April/007506.html>

We know that all the following were valid under the old method 6:

- Allowing the certificate requester to specify the URI.  For example, if the 
certificate wanted shop.example.com <http://shop.example.com/>, the requester 
could say “check at http://shop.example.com/tmp/uploads/foo.txt 
<http://shop.example.com/tmp/uploads/foo.txt>” for the agreed upon change

- Looking for the change anywhere in the page.  The CA would give the requester 
a token to put on the website and then look for it to appear somewhere on the 
page.  This is a huge problem for sites that have public comments, message 
boards, or user-editable content.  For example, validate “control” of 
www.ibm.com <http://www.ibm.com/> by posting a message containing the token at 
https://www.ibm.com/developerworks/community/forums/html/public 
<https://www.ibm.com/developerworks/community/forums/html/public>

- Simply looking for the existence of a  file by name.  For example telling the 
customer to create http://<FQDN>/adfa24r43aefwaer2442.txt and not caring about 
the content.

- Looking for a content to be returned from the server that was included in the 
URL and not checking the HTTP return code.

I would also note that other “old” methods have similar issues.  For example, 
there was no requirement that email validation used a unique token per request. 
 It would have been valid to send an email saying “Does this email work?” to 
the domain owner and using an out-of-office auto-reply as proof of 
“communication”, as the requirement was only “Communicating with” the email 
address.

Does that help explain the concern?

Thanks,
Peter

> From: Ryan Sleevi [mailto:[email protected] <mailto:[email protected]>] 
> Sent: Friday, April 28, 2017 6:09 AM
> To: Kirk Hall <[email protected] 
> <mailto:[email protected]>>
> Cc: CA/Browser Forum Public Discussion List <[email protected] 
> <mailto:[email protected]>>; Wayne Thayer <[email protected] 
> <mailto:[email protected]>>
> Subject: [EXTERNAL]Re: [cabfpub] Ballot 190
>  
>  
>  
> On Fri, Apr 28, 2017 at 1:32 AM, Kirk Hall <[email protected] 
> <mailto:[email protected]>> wrote:
> One other comment.  Remember that for the last few months, new Methods 1-4 
> and 7-10 were actually included under Method 11 “any other method” after 
> Ballot 181’s effective date, and that situation will continue until the 
> effective date of Ballot 190.  Also, the same is true for any validations 
> that followed old Method 7 “any other method” prior to the effective date of 
> Ballot 169.  So be very careful in saying anything in Ballot 190 that would 
> invalidate validations done prior to Ballot 190 under “any other method” so 
> long as they complied with any of Methods 1-10 of the new methods or Methods 
> 1-6 of the old methods.
>  
> I would be open to saying that any prior vetting done under old Method 7 or 
> more recent Method 11 “any other method” must be revalidated upon the 
> effective date of Ballot 190 IF they did not follow EITHER Methods 1-6 (as 
> the existed before Ballot 169) or Methods 1-10 (as put forward in Ballot 
> 169).  In other words, the ONLY validations that have to be redone before the 
> expiration of the re-use period are validations that were done that did not 
> comply with either old Methods 1-6 or new Methods 1-10.  That should flush 
> out any unknown and unsecure validations that occurred in the past.
>  
> Not quite, because if you recall, Google's interest in reforming these began 
> with the fact that a website demonstration of control was not secure. That 
> is, 3.2.2.4.6 under pre-169 is not acceptable.
>  
> Kirk, given your support for other forms of indicating that a CA has 
> performed extra diligence, such as the inclusion of OV certificates, would 
> you be supportive in general of a means of expressing, within a certificate, 
> conformance with the 'new' validation methods, so that subscribers can have 
> assurances of the security? 
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