> On 19 May 2017, at 3:43 pm, Ryan Sleevi <[email protected]> wrote:
> 
> How does that fit with the quoted Section 4.1.2?
> 
> "The  certificate     request MUST contain a request from, or on behalf of, 
> the Applicant for the issuance of a Certificate, and a certification by, or 
> on behalf of, the Applicant that all of the information contained therein is 
> correct.”

4.1.2 starts with “Prior to the issuance of a Certificate”.  So, at some point 
before the certificate issues, 4.1.2 needs to be satisfied.  There’s no 
ordering between that and the validation requirements in the BRs.

> 1) If there is no certificate request, is there an Applicant at the time the 
> CA begins validating information?

A validation is only relevant to the BRs if it leads to a certificate issuance. 
 A certificate issuance must only occur after a certificate request which 
implies the existence of an Applicant to get the certificate request from.  So, 
yes, there must have been an Applicant.  The CA may not have known who.

> 2) If there is no certificate request, and/or there is no Applicant, how is 
> the information the CA validated conforming with Section 3.2, which Section 
> 4.2.1 references?

There is always an Applicant and there must be a certificate request, see above.

> Those are two reasons why I do not believe the scenario is permitted.

Those weren’t reasons, they were questions…

> On Fri, May 19, 2017 at 6:37 PM, Geoff Keating <[email protected] 
> <mailto:[email protected]>> wrote:
> Hi Ryan,
> 
> I don’t think there’s anything in the BRs that says that particular 
> validation steps must happen before other steps, so long as the appropriate 
> time limits are honored.  Your example where a CA finds an existing 
> certificate for a prospective customer, validates everything in that 
> certificate (for example checking domain name against organization name using 
> whois), and then contacts the prospective customer (for example, via postal 
> address in company registration, matched against whois) and asks if they’d 
> like a replacement certificate and if all the details are correct, seems 
> permitted to me.
> 
> 

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