3. BR 3.2.2.4.1 is performed using registrar information to confirm the 
organization has registered the domain name. The QIIS is used to identify 
relationships if the domain is registered to a parent or subsidiary.

- This is the hand-wavy part. Looking in WHOIS to see some org listed does not 
tie the org to the domain. Anyone can list anything in the WHOIS corporate 
details.  

 

4.BR 3.2.5 is performed by finding contact information for the organization 
using a QIIS. The authorization contact is called at the organization using 
this information. The authorization contact is asked to confirm that a 
certificate with the organization name, using the domain name(s) requested, can 
be issued to the certificate requester. 

- Do you do this step for every domain? I’m guessing it’s done once every 825 
days when you verify the org to confirm the account is controlled by that org.  
Is there any tie between the person called and the domain name other than that 
the person called requested the certificate for the domain? 

 

What’s missing from this process is any awareness of the domain owner that a 
certificate is being requested by Company ABC.  Because WHOIS is unverified 
information with respect to company info, there’s no actual technical tie 
between the org and the domain. Because names are not globally unique, there’s 
no determination whether the correct entity applied for the certificate (ie - 
DigiCert, Inc. a Utah corp and DigiCert, Inc. a Malaysian entity). 

 

From: Public [mailto:public-boun...@cabforum.org] On Behalf Of Bruce Morton via 
Public
Sent: Thursday, January 4, 2018 7:49 AM
To: Ryan Sleevi <sle...@google.com>
Cc: CA/Browser Forum Public Discussion List <public@cabforum.org>
Subject: Re: [cabfpub] [EXTERNAL]Re: Ballot 218: Remove validation methods #1 
and #5

 

Hi Ryan,

 

Here are some details on how we perform this method.

 

For an OV certificate, we perform method #1 as follows:

 

1.      Order is received with the subject name, SANs, a certificate requester 
and an authorization contact. The authorization contact must be employed by the 
organization in the subject name.
2.      BR 3.2.2.1 is performed to confirm the identity of the organization. 
This task is done with using a QIIS.
3.      BR 3.2.2.4.1 is performed using registrar information to confirm the 
organization has registered the domain name. The QIIS is used to identify 
relationships if the domain is registered to a parent or subsidiary.
4.      BR 3.2.5 is performed by finding contact information for the 
organization using a QIIS. The authorization contact is called at the 
organization using this information. The authorization contact is asked to 
confirm that a certificate with the organization name, using the domain name(s) 
requested, can be issued to the certificate requester. 

 

 

Thanks, Bruce.

 

From: Ryan Sleevi [mailto:sle...@google.com] 
Sent: January 4, 2018 12:09 AM
To: Bruce Morton <bruce.mor...@entrustdatacard.com 
<mailto:bruce.mor...@entrustdatacard.com> >
Cc: Rich Smith <richard.sm...@comodo.com <mailto:richard.sm...@comodo.com> >; 
CA/Browser Forum Public Discussion List <public@cabforum.org 
<mailto:public@cabforum.org> >; Kirk Hall <kirk.h...@entrustdatacard.com 
<mailto:kirk.h...@entrustdatacard.com> >
Subject: Re: [EXTERNAL]Re: [cabfpub] Ballot 218: Remove validation methods #1 
and #5

 

 

 

On Wed, Jan 3, 2018 at 5:27 PM, Bruce Morton <bruce.mor...@entrustdatacard.com 
<mailto:bruce.mor...@entrustdatacard.com> > wrote:

I disagree.

 

Removing, changing and adding back in method #1 is not a productive exercise. 
This method has been used for probably 20 years and yet we never see any 
notifications, articles, alerts, etc. of how this method was defeated by an 
attacker.

 

I think it's exceptionally dangerous to rest on that, particularly since CAs 
such as Entrust don't make available to the public their processes and controls 
to inspect whether or not they're vulnerable. I am greatly appreciative to 
Jeremy sharing the case of customers from a CA they acquired not being 
validated to the level that DigiCert holds itself - but that's hardly to be 
expected, unless we are to suggest DigiCert should buy out every other CA.

 

It was this philosophical opposition that resulted in MD5 being exploited 'in 
the wild' - CAs ignoring the literature and research and demanding 'proof it 
applied'

 

Does Entrust (or the CAs it has acquired) use this method? Can you share the 
details that are used to do this?

 

I stand by the assertion that while it may be possible to restrict what is done 
under 3.2.2.4.1 to be 'secure', that is not what it is in the language, and 
what is presently executed is demonstrably insecure. If we are to suggest that 
we, as an industry, care about security of our users, then we should make 
tradeoffs that favor security.

 

 

Note, I agree that method #1 can be approved in the BRs, but please advise 
which CAs have not already improved this method in practice? If a CA finds a BR 
requirement to be weak, they should either not use it or improve the process in 
their own practices. I assume that many BR requirements were not intended to 
have loopholes, but were written to allow competitiveness in the way they are 
adopted.

 

Fundamentally, I disagree with this framing. System security works by ensuring 
the minimum level of security is appropriate - not that every CA will be smart 
enough, well-versed in the nuance enough, and/or financially motivated enough 
to 'not be creative'.

 

I think that the current ballot 218 is bypassing the working group process 
where a working group was created by ballot to improve the validation methods. 
Is this the intension?

 

This is not, nor has it never been, required by our Bylaws. There have been 
suggestions from some CAs to try to do this, but this has historically turned 
out to be a stalling tactic.

 

Does Entrust employ 3.2.2.4.1? If so, given that it's required to track the 
validation methods it uses, can you share approximately how many or what 
percentage of certs you use it for, and how you use it? This can go leaps and 
bounds to providing meaningful data about the potential impact to the ecosystem 
from disallowing it, without the deliberative delays.

 

 

If we are going to support abrupt ballots, then I would suggest that they at 
least be split into one topic and discuss method #1 and #5 independently.

 

Finally, what is the rush? Why can’t this change be discussed at the bi-weekly 
CAB Forum meeting or Validation Working Group meeting at least once before a 
pre-ballot is produced? And why effective March 1, 2018? Not only has method #1 
been highly effective for 20 years, but we have also just updated the 
validation methods to support ballot 190. More time would allow CAs to add 
changes to their release cycles and allow Subscribers to learn new validation 
processes they will now have to adopt.

 

Security comes first. That sounds like a considerable stalling tactic, to be 
honest. Is this because Entrust specifically uses 3.2.2.4.1, or are you 
opposing it on procedural grounds? This, too, will help understand both the 
substance of the objections and potential paths to addressing them.

 

 

I am open to change BR requirements, but do not support ballot 218.

 

Bruce.   

 

From: Public [mailto:public-boun...@cabforum.org 
<mailto:public-boun...@cabforum.org> ] On Behalf Of Rich Smith via Public
Sent: January 3, 2018 4:44 PM
To: 'Ryan Sleevi' <sle...@google.com <mailto:sle...@google.com> >; 'CA/Browser 
Forum Public Discussion List' <public@cabforum.org <mailto:public@cabforum.org> 
>; Kirk Hall <kirk.h...@entrustdatacard.com 
<mailto:kirk.h...@entrustdatacard.com> >
Subject: [EXTERNAL]Re: [cabfpub] Ballot 218: Remove validation methods #1 and #5

 

I agree with Ryan on this and stand by my endorsement of this ballot to move 
forward.  I’m not opposed to adding 3.2.2.4.1 back in if it can be made much 
more secure and brought up to equivalent level with the other methods, but I 
also have my doubts as to whether or not that is possible in the broad sense 
across all TLDs and registrars.  That being the case I think the best course is 
to remove it for now because in it’s present form is extremely weak and add 
back later if and when it has undergone sufficient revisions to make it secure.

 

Regards,

Rich

 

From: Public [mailto:public-boun...@cabforum.org] On Behalf Of Ryan Sleevi via 
Public
Sent: Wednesday, January 3, 2018 2:24 PM
To: Kirk Hall <kirk.h...@entrustdatacard.com 
<mailto:kirk.h...@entrustdatacard.com> >; CA/Browser Forum Public Discussion 
List <public@cabforum.org <mailto:public@cabforum.org> >
Subject: Re: [cabfpub] Ballot 218: Remove validation methods #1 and #5

 

Hi Kirk,

 

We had two endorsers for the discussion. As I mentioned, there's nothing 
inherent in needing to direct this to VWG. As DigiCert has pointed out, there 
are CAs today that are doing validations that are patently insecure.

 

While we can understand and appreciate that some members may wish to introduce 
new validation methods that are limited in scope and applicability (for 
example, Mads' example only applies to a limited subset of ccTLDs, and cannot 
be done safely generically), in order to reduce that risk, I think it's 
entirely appropriate to take the necessary steps to ensure the safety of the 
Internet at large.

 

This does not prevent or inhibit the issuance of certificates that have 
appropriate controls - that is, these methods could be argued as an 
'optimization' - and thus we should not unduly delay progress. Regarding 
passing it to the VWG, could you indicate where you saw that was suggested? The 
only mention of it I saw was from you, on a separate thread, and I'm curious if 
perhaps I've missed additional discussion. Certainly, our workmode does not 
require sending such discussions "to committee"

 

On Wed, Jan 3, 2018 at 3:10 PM, Kirk Hall via Public <public@cabforum.org 
<mailto:public@cabforum.org> > wrote:

Tim, I thought this issue was going to be discussed first by the VWG, as 
several CAs have indicated they would like to keep (but improve) Method 1.  

 

From: Public [mailto:public-boun...@cabforum.org 
<mailto:public-boun...@cabforum.org> ] On Behalf Of Tim Hollebeek via Public
Sent: Wednesday, January 3, 2018 11:22 AM
To: CA/Browser Forum Public Discussion List <public@cabforum.org 
<mailto:public@cabforum.org> >
Subject: [EXTERNAL][cabfpub] Ballot 218: Remove validation methods #1 and #5

 

 

Ballot 218: Remove validation methods #1 and #5

 

Purpose of Ballot: Section 3.2.2.4 says that it “defines the permitted 
processes and procedures for validating the Applicant’s ownership or control of 
the domain.”  Most of the validation methods actually do validate ownership and 
control, but two do not, and can be completed solely based on an applicant’s 
own assertions.

 

Since these two validation methods do not meet the objectives of section 
3.2.2.4, and are actively being used to avoid validating domain control or 
ownership, they should be removed, and the other methods that do validate 
domain control or ownership should be used.

 

The following motion has been proposed by Tim Hollebeek of DigiCert and 
endorsed by Ryan Sleevi of Google and Rich Smith of Comodo.

 

-- MOTION BEGINS –

 

This ballot modifies the “Baseline Requirements for the Issuance and Management 
of Publicly-Trusted Certificates” as follows, based upon Version 1.5.4:

 

In Section 3.2.2.4.1, add text at the end: “For certificates issued on or after 
March 1, 2018, this method SHALL NOT be used for validation, and completed 
validations using this method SHALL NOT be used for the issuance of 
certificates.”

 

In Section 3.2.2.4.5, add text at the end: “For certificates issued on or after 
March 1, 2018, this method SHALL NOT be used for validation, and completed 
validations using this method SHALL NOT be used for the issuance of 
certificates.”

 

In Section 4.2.1, after the paragraph that begins “After the change to any 
validation method”, add the following paragraph: “Validations completed using 
methods specified in Section 3.2.2.4.1 or Section 3.2.2.4.5 SHALL NOT be 
re-used on or after March 1, 2018.”

 

-- MOTION ENDS –

 

For the purposes of section 4.2.1, the new text added to 4.2.1 from this ballot 
is “specifically provided in a [this] ballot.”

 

The procedure for approval of this ballot is as follows:

 

Discussion (7+ days) 

  Start Time: 2017-01-03  19:30:00 UTC  

  End Time: Not Before 2017-01-10 19:30:00 UTC

 

Vote for approval (7 days) 

  Start Time: TBD   

  End Time: TBD

 


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