Ben,

I would suggest a couple of changes:

1) Underscores should only be allowed where hyphens are allowed.  Notable 
hyphens and underscores cannot start or end a label.  I suggest `one or more 
underscore characters (“_”) may be present in the FQDN in positions permitted 
to contain a hyphen character`

2) I would suggest adding a definition of Wildcard Domain Name and then using 
it here.  `Wildcard Domain Name: A Domain Name formed by prepending "*." to a 
FQDN`

Thanks,
Peter

> On May 25, 2017, at 1:08 PM, Ben Wilson via Public <[email protected]> 
> wrote:
> 
> I’m looking for two endorsers for Ballot 202 – Underscore Characters in SANS
> The current Baseline Requirements do not expressly allow underscore 
> characters in Subject Alternative Names. This ballot seeks to clarify that 
> one or more underscore characters (“_”) are allowed in FQDNs.  It also cleans 
> up some of the language in Section 7.1.4.2.1 of the Baseline Requirements.
> 
> The following motion has been proposed by Ben Wilson of DigiCert and endorsed 
> by - and - to introduce new Final Maintenance Guidelines for the "Baseline 
> Requirements Certificate Policy for the Issuance and Management of 
> Publicly-Trusted Certificates" (Baseline Requirements). 
> 
> --Motion Begins-- 
> 
> REPLACE Section 7.1.4.2.1 of the Baseline Requirements in its entirety with: 
> 
> 7.1.4.2.1 Subject Alternative Name Extension 
> 
> Certificate Field: extensions:subjectAltName 
> 
> Required/Optional: Required 
> 
> Contents: This extension MUST contain at least one entry. Each entry MUST be 
> either a dNSName or iPAddress name. 
> 
> For entries of the type dNSName, the entry MUST containing the 
> Fully-Qualified Domain Name that the CA has validated in accordance with 
> section 3.2.2.4. The FQDN must comply with RFC 5280, Section 4.2.1.6, 
> including that the name be in “preferred name syntax,” with the following 
> exceptions: a single wildcard character (“*”) MAY be present as the 
> left-most, most subordinate level, if the CA has validated the name 
> consistent with Section 3.2.2.6; and one or more underscore characters (“_”) 
> may be present in the FQDN, in deviation from the “preferred name syntax”. 
> The entry MUST NOT contain an Internal Name. 
> 
> For entries of the type iPAddress, the entry MUST contain an IP address that 
> the CA has validated in accordance with Section 3.2.2.5. The entry MUST NOT 
> contain a Reserved IP Address. 
> 
> --Motion Ends-- 
> 
> Thanks,
>  
> Ben
>  
> From: Public [mailto:[email protected]] On Behalf Of Ben Wilson via 
> Public
> Sent: Thursday, April 20, 2017 12:09 PM
> To: Ryan Sleevi <[email protected]>; CA/Browser Forum Public Discussion List 
> <[email protected]>
> Cc: Ben Wilson <[email protected]>
> Subject: Re: [cabfpub] Pre-Ballot: Underscore Characters in SANs
>  
> Thanks.  I’ll rework this with the language suggested and re-circulate.
> Ben
>  
> From: Ryan Sleevi [mailto:[email protected]] 
> Sent: Thursday, April 20, 2017 11:36 AM
> To: CA/Browser Forum Public Discussion List <[email protected]>
> Cc: Ben Wilson <[email protected]>
> Subject: Re: [cabfpub] Pre-Ballot: Underscore Characters in SANs
>  
>  
>  
> On Thu, Apr 20, 2017 at 1:07 PM, Ben Wilson via Public <[email protected]> 
> wrote:
> All,
>  
> I’m looking for two endorsers for a proposed amendment to section 7.1.4.2.1 
> of the Baseline Requirements--to be modified to allow the underscore 
> character (“_”) in SANs and to remove the sunset language in that section 
> related to internal names and reserved IP addresses.  The revised section 
> 7.1.4.2.1 would read as follows:
>  
> 
> 7.1.4.2.1.             Subject Alternative Name Extension
> Certificate Field: extensions:subjectAltName
> Required/Optional:  Required
> Contents:  This extension MUST contain at least one entry.  Each entry MUST 
> be either a dNSName containing the Fully-Qualified Domain Name or an 
> iPAddress containing the IP address of a server.  The CA MUST confirm that 
> the Applicant controls the Fully-Qualified Domain Name or IP address or has 
> been granted the right to use it by the Domain Name Registrant or IP address 
> assignee, as appropriate.
> Wildcard FQDNs and underscores in FQDNs (encoded as IA5 strings) are 
> permitted.  
> CAs SHALL NOT issue a certificate with a subjectAlternativeName extension or 
> Subject commonName field containing a Reserved IP Address or Internal Name. 
> 
> Ben,
>  
> Some suggested edits that may help resolve any future ambiguities, capturing 
> the discussions from the Raleigh F2F.
>  
> """
> 7.1.4.2.1 Subject Alternative Name Extension
> Certificate Field: extensions:subjectAltName
> Required/Optional: Required
> Contents: This extension MUST contain at least one entry. The entry MUST be 
> either a dNSName or iPAddress name.
>  
> For entries of the type dNSName, the entry MUST contain the Fully-Qualified 
> Domain Name that CA has validated the Applicant's control or ownership of. 
> The Fully-Qualified Domain Name must comply with RFC 5280, Section 4.2.1.6, 
> including that of requiring the name be in the "preferred name syntax," with 
> the following exceptions: A single wildcard ('*') character may be present as 
> the left-most, most subordinate label, if the CA has validated the name 
> consistent with Section 3.2.2.6. One or more underscore ('_') characters may 
> be present within the Fully-Qualified Domain Name, in deviation from the 
> "preferred name syntax." The entry MUST NOT contain an Internal Name.
>  
> For entries of the type iPAddress, the entry MUST contain an IP address that 
> the CA has validated the Applicant's control of. The entry MUST NOT contain a 
> Reserved IP Address.
> """
>  
> Here's a bit of explanation for the edits and why I made them:
> - Split the rules regarding dNSName and iPAddress into two separate sections, 
> to make it unambiguous the contents they can contain
> - Clarify that wildcards and underscores are NOT permitted for the type 
> iPAddress
> - Clarify that domain names MUST follow the rules of RFC 5280, particularly 
> that of preferred name syntax. This includes the prohibition of the " " label 
> or that of e-mail addresses in the domain form (both examples given in RFC 
> 5280). It clarifies that the exceptions to this rule are limited to the 
> presence of wildcard characters and underscores.
>   * There's one issue which I debated trying to tackle in this, which is that 
> it's possible for an applicant to register the literal "*.domain.com" (e.g. 
> the actual wildcard character). The current and proposed wording fail to 
> address this in 3.2.2.6, even though the intent is clearly that in the case 
> of a *, the CA MUST validate the Applicant's control of the Domain Namespace 
> indicated by removing the '*' label.
>   * Happy to suggest wording if it's clear the concern here
> - Reuse the language from 3.2.2.4 and 3.2.2.5, specifically the "Applicant's 
> control or ownership of" a domain name and "control of" an IP address.
>   - The existing wording, "granted the right to use", is ambiguous, because 
> no process is defined within the BRs as to how an Applicant can demonstrate 
> such a grant, or how the CA can verify such a grant.
>   - I believe the intent is with respect to reusing the validation methods of 
> 3.2.2.4, but if CAs feel that this is an intentional loophole to permit some 
> activity that would otherwise be prohibited or underspecified, I'm happy to 
> see what we can figure out
> - Lays out a framework for permitting additional name types in the future, as 
> discussed. This section could be tightened up further to support that future 
> growth, but I tried to keep it mostly minimal for now, so that we could 
> incrementally improve.
>  
> Do let me know what you think of those edits, and whether they bring the 
> necessary clarity of intent and execution.
>  
> <Underscore Characters in 
> SANs.pdf>_______________________________________________
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