Can we also include a validation method based on the one I suggested a couple 
of months ago in https://cabforum.org/pipermail/public/2017-October/012423.html 
<https://cabforum.org/pipermail/public/2017-October/012423.html> ?  That method 
would provide a strong link between Registry/Registrar and CA even when they 
are not affiliates.

Thanks,
Peter

> On Jan 10, 2018, at 4:32 PM, Daymion T. Reynolds via Public 
> <[email protected]> wrote:
> 
> I am in agreement with this approach.  Thanks Ryan for wrapping this up.
> Daymion
>  
> From: Ryan Sleevi [mailto:[email protected] <mailto:[email protected]>] 
> Sent: Wednesday, January 10, 2018 4:49 PM
> To: Daymion T. Reynolds <[email protected] <mailto:[email protected]>>
> Cc: CA/Browser Forum Public Discussion List <[email protected] 
> <mailto:[email protected]>>; Kirk Hall <[email protected] 
> <mailto:[email protected]>>; Tim Hollebeek 
> <[email protected] <mailto:[email protected]>>
> Subject: Re: [cabfpub] Ballot 218: Remove validation methods #1 and #5
>  
> So to make sure I've captured the discussion points of 3.2.2.4.1 for the 
> "things that would be disruptive"
>  
> For situations like GoDaddy (in which the CA is the Registrar as well) - or 
> for situations like, say, Google Trust Services/Google, in which the CA is an 
> Affiliate of the Registrar (I think; I'm sure folks like Amazon with its 
> Amazon Trust Services is in a similar space, and no doubt others) - the 
> 'goal' is that if the CA believes the Applicant is the same entity as the 
> Domain Owner, then it can use that as an effective authorization by virtue of 
> the fact that it's the same account that would approve that operation.
>  
> For situations like the ccTLDs, particularly those that lack WHOIS, or for 
> situations like .gov, it's seen as acceptable that contacting the registry to 
> determine who the Domain Name Registrant is, and then using 
> 3.2.2.4.2/3.2.2.4.3 methods of validation/contact is seen as viable.
>  
> Finally, we have the issue that most folks (all?) seem to agree that 
> 3.2.2.4.1 Option 1/Option 2 are not reliably secure, and neither is 3.2.2.5. 
> Unfortunately, because of the 'grandfathering' validation clause, this makes 
> it difficult to unambiguously ensure (re)validation of domains if they use an 
> insecure method.
>  
> Daymion, do you think a ballot that:
> - Deprecated 3.2.2.4.1 as previously proposed (e.g. "adding not after March")
> - Deprecated 3.2.2.4.5 as previously proposed (e.g. "adding not after March")
> - Make the change to Contact as previously discussed, namely: "Domain 
> Contact: The Domain Name Registrant, technical contact, or administrative 
> contract (or the equivalent under a ccTLD) as listed in the WHOIS record of 
> the Base Domain Name or in a DNS SOA record, or as obtained through direct 
> contact with the Domain Name Registrar."
> - Introduce 3.2.2.4.11 (a new method), which reads (to be smithed a little if 
> necessary):
>  
> "3.2.2.4.11 Validating Applicant as a Domain Contact
> Confirming the Applicant's control over the FQDN by validating the Applicant 
> is the Domain Contact. This method may only be used if the CA is also the 
> Domain Name Registrar, or an Affiliate of the Registrar, of the Base Domain 
> Name.
>  
> Note: Once the FQDN has been validated using this method, the CA MAY also 
> issue Certificates for other FQDNs that end with all the labels of the 
> validated FQDN. This method is suitable for validating Wildcard Domain Names."
>  
>  
> Yes, this doesn't describe how the CA/Registrar (or CA-Affiliate/Registrar) 
> precisely performs this validation, but I'm hesitant to add wording such as 
> 'accounts' or 'usernames' or equivalent access control levels at this time, 
> and can live with being permissive here and then iterating to be tighter 
> around this language. My goal here would be to make it clear that Option #1 
> and Option #2 of 3.2.2.4.1 are unacceptable, but unfortunately the poor 
> wording of 3.2.2.4 and 4.2.1 means we have to effectively remove/forbid 
> 3.2.2.4.1 entirely and then re-add the bits that make sense.
>  
> On Wed, Jan 10, 2018 at 6:16 PM, Daymion T. Reynolds <[email protected] 
> <mailto:[email protected]>> wrote:
> Ryan,
>  
> Q: Can you explain why you do not believe it is more secure? 
> A: I am not stating its more secure, but .1 Option #3 is on par with other 
> deemed secure options. It is secure because only the domain owner is the 
> authorized user to a registrars account, and only they can order a cert for a 
> specific domain. If more transparency is a concern, let’s discuss what would 
> be acceptable.
>  
> Q: I don't believe this is universally the case. Consider the situation of 
> registrars and registries that allow signing in without a 2FA, but require 
> changes to use a 2FA. I realize a response might be "Well, the registrar 
> could just require 2FA for issuing a cert" - and while that would be in 
> theory possible, there's absolutely zero assurance for relying parties and 
> browsers as to the registrars (and CAs) practices. I hope you can see why 
> this remains a fundamentally problematic proposal.
> A: I agree, everyone should be using 2FA. Unpacking this a bit further, as 
> your statement is close to the crux of my argument. If the registrar account 
> is compromised, everything about the domain is in question. If registrar 
> account compromise is a concern for .1 option #3 then it also a question for 
> .4 Domain Contact, .7 DNS Change and .8 IP Address validation. All of these 
> require the registrar account to be secure. I believe .4, .7, and .8 are 
> secure practices. 
>  
> Q: I think it's important to be precise here when talking about .1. Is it 
> correct to say you are only concerned with retaining some notion of .1 Option 
> 3? When we say "don't eliminate .1", I think that carries with it the 
> significant (and insecure) suggestion of retaining .1 Option 1 and .1 Option 
> 2.
> A: Agreed, and sorry for not being precise. You are correct I am only 
> concerned with Option #3, as I believe it is a secure practice on par with .7 
> and .8. I agree with your position on option #1 & #2.
>  
> Thanks for your time discussing this,
> Daymion
>  
>  
>  
>  
> From: Ryan Sleevi [mailto:[email protected] <mailto:[email protected]>] 
> Sent: Wednesday, January 10, 2018 1:50 PM
> To: Daymion T. Reynolds <[email protected] <mailto:[email protected]>>
> Cc: CA/Browser Forum Public Discussion List <[email protected] 
> <mailto:[email protected]>>; Kirk Hall <[email protected] 
> <mailto:[email protected]>>; Tim Hollebeek 
> <[email protected] <mailto:[email protected]>>
> Subject: Re: [cabfpub] Ballot 218: Remove validation methods #1 and #5
>  
>  
>  
> On Wed, Jan 10, 2018 at 2:37 PM, Daymion T. Reynolds <[email protected] 
> <mailto:[email protected]>> wrote:
> Ryan,
>               Thank you for replying as this is a good discussion to have. 
> “Direct contact” is great method when you don’t have a clean, reliable data 
> source to validate ownership. For Registrar / CA combos, whereby the same 
> account ordered the domain and the cert, knowledge of ownership is robust. 
> Requiring a second contact doesn’t seem more secure, but rather seems more 
> cumbersome for an already complex process.
>  
> Can you explain why you do not believe it is more secure?
>  
> If you are concerned about the possibility of a customer account being 
> compromised, it doesn’t change the risk. If there was a compromise they would 
> have control over DNS and could then domain validate a cert order from anyone.
>  
> I don't believe this is universally the case. Consider the situation of 
> registrars and registries that allow signing in without a 2FA, but require 
> changes to use a 2FA. I realize a response might be "Well, the registrar 
> could just require 2FA for issuing a cert" - and while that would be in 
> theory possible, there's absolutely zero assurance for relying parties and 
> browsers as to the registrars (and CAs) practices. I hope you can see why 
> this remains a fundamentally problematic proposal.
>  
>               Rather than eliminate .1, I believe a better course of action 
> would be to add transparency and lock down when you can and cannot use the 
> registrar validation method.
>  
> I think it's important to be precise here when talking about .1. Is it 
> correct to say you are only concerned with retaining some notion of .1 Option 
> 3? When we say "don't eliminate .1", I think that carries with it the 
> significant (and insecure) suggestion of retaining .1 Option 1 and .1 Option 
> 2.
>  
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