Gerv,

I think this still presents problems for vanity CAs.  I can agree with the need 
to validate the entity in the O field (i.e. that the root CA has permission to 
create a CA with the sub CA's tradename), but I would want to preserve some 
flexibility.  Right now, the language I'm concerned about says, "This field 
MUST be present and the contents MUST contain either the Subject CA’s name or 
DBA as verified under Section 3.2.2.2."  How strict will this be interpreted / 
applied?
Also, I assume an internally operated CA with a vanity CA name would still be 
included in the root CA's audits but what BR-related obligations might be 
unintentionally incurred by the entity listed in the O field. 

Ben

-----Original Message-----
From: Gervase Markham [mailto:[email protected]] 
Sent: Friday, May 5, 2017 7:23 AM
To: Ben Wilson <[email protected]>; CA/Browser Forum Public Discussion 
List <[email protected]>
Subject: Re: [cabfpub] Ballot 199 - Require commonName in Root and Intermediate 
Certificates

On 04/05/17 16:20, Ben Wilson wrote:
> 1 - Does this ballot rule out “vanity CAs” – CAs with customer names 
> in the subject field, even though the key is held by the root CA?  (I 
> can provide further clarification, and/or examples, if necessary.

I don't think so. It doesn't mandate the contents of the CN field other than a 
SHOULD-based uniqueness constraint.

> 2-  What is the full current wording of Ballot 199?

It is as posted on 25th April, but with a MUST changed to a SHOULD. I will send 
out a full copy.

Gerv

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