Hi Rich

I understand your concern and position. 

I don't think the proposed new text for 3.2.2.4.1 by itself adds any new 
assumption, but the overall process for issuing OV/EV certificates might be 
subject to this. In your example the link between company A (the one you 
register) and company B (the target) could be established by social engineering 
independent of the proposed text. I could argue that the CA should treat 
Company A as the Applicant and not Company B. In that case the method cannot be 
used. If the CA treat Company B as the Applicant, then it should be difficult 
to get the authenticity of the certificate request established. 

In my opinion, your last statement summarizes what the discussion really is 
about. Should we allow issuance of an SSL certificate based on domain ownership 
by the Applicant at all or should this only be allowed based on some technical 
demonstration of domain control? I think this is the core issue. 

Regards
Mads

-----Original Message-----
From: Rich Smith [mailto:[email protected]] 
Sent: fredag 19. januar 2018 20:37
To: Mads Egil Henriksveen <[email protected]>; 'CA/Browser Forum 
Public Discussion List' <[email protected]>; 'Gervase Markham' 
<[email protected]>
Subject: RE: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain 
Authorization Document

Mads,
I appreciate you trying to save this method, but IMO there is nothing that can 
be done to strengthen this method enough to protect it against social 
engineering.  Your proposal relies on the assumption that EVERY validation 
agent of EVERY CA MUST have at least the same level of understanding of 
corporate structures as the people in this Forum.  It's an unrealistic 
assumption.  All I have to do is register a company called Google, Inc., in 
SOME jurisdiction, get listed in SOME QIIS, then just convince a validation 
agent from ANY CA that I am a local branch office of the real Google, Inc.
that we all know and love and bam, I've got a cert for google.com.

I picked Google because they are an easy example.  In reality I suspect
(hope) that no CA would fall for this particular example, but a less known 
company?  Almost certainly.

Through the discussion I've been convinced that we should leave some version of 
3.2.2.4.1 (3) in place, but I don't think you'll ever convince me that the 
other bits of 3.2.2.4.1 or 3.2.2.4.5 are, or ever can be made to be, as secure 
as the weakest technical demonstration of domain control.

Regards,
Rich

-----Original Message-----
From: Public [mailto:[email protected]] On Behalf Of Mads Egil 
Henriksveen via Public
Sent: Friday, January 19, 2018 6:59 AM
To: Gervase Markham <[email protected]>; CA/Browser Forum Public Discussion List 
<[email protected]>
Subject: Re: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain 
Authorization Document

Hi Gerv

The current version 3.2.2.4.1 says:
----
3.2.2.4.1 Validating the Applicant as a Domain Contact Confirming the 
Applicant's control over the FQDN by validating the Applicant is the Domain 
Contact directly with the Domain Name Registrar. 

This method may only be used if:
1. The CA authenticates the Applicant's identity under BR Section 3.2.2.1 and 
the authority of the Applicant Representative under BR Section 3.2.5, OR 2. The 
CA authenticates the Applicant's identity under EV Guidelines Section
11.2 and the agency of the Certificate Approver under EV Guidelines Section 
11.8; OR 3. 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.
-----
 
Our proposal concentrates on the first part, i.e. the following statement: 
>> Confirming the Applicant's control over the FQDN by validating the
Applicant is the Domain Contact directly with the Domain Name Registrar.

Is to be replaced with:
<< Conforming the Applicant's control over the FQDN by validating the Applicant 
as the Domain Name Registrant by verifying that: 
<< 1.   The name of the Domain Name Registrant matches the Applicant's name
AND
<< 2.   Additional information about the Domain Name Registrant in the WHOIS
meet the following requirements:
<<          i.  The Registrant's postal address in the WHOIS belongs to the
Applicant. CAs MUST verify this by matching it with one of the Applicant's 
addresses in: (a) a QGIS, QTIS, or QIIS; or (b) a Verified Professional Letter. 
<<                         Note: Address details in the WHOIS are required
to use this option. Address details must include at a minimum the Country and 
either Locality, State or Province. OR 
<<          ii. The WHOIS contains the Registration (or similar) Number
assigned to the Applicant by the Incorporating or Registration Agency in its 
Jurisdiction of Incorporation or Registration as appropriate. CAs MUST verify 
this by matching the Registration Number in the WHOIS with the Applicant's 
Registration Number in a QGIS or a QTIS.

The first change is the use of Domain Name Registrant instead of Domain 
Contact, i.e. the focus is on domain ownership. 

The proposal requires that the name of the Registrant (in WHOIS) matches 1) the 
name of the Applicant AND either 2 i) the postal address of the Registrant (in 
WHOIS) matches the postal address of the Applicant (in sources accepted for EV 
validation) OR 2 ii) a Registration Number for the Registrant (in WHOIS) 
matches the Registration Number of the Applicant (in a QGIS or QTIS).

The proposal addresses threats due to that organization names are not unique, 
the combination of organization name and address or organization name and 
registration number should be unique. It also removes ambiguities the current 
language permits (according to Jeremy - see attachment). 

Regards
Mads 

-----Original Message-----
From: Public [mailto:[email protected]] On Behalf Of Gervase Markham 
via Public
Sent: fredag 19. januar 2018 10:29
To: Mads Egil Henriksveen via Public <[email protected]>
Subject: Re: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain 
Authorization Document

On 19/01/18 06:51, Mads Egil Henriksveen via Public wrote:
> Buypass, Entrust Datacard and GlobalSign have been working on some 
> text to strengthen 3.2.2.4.1 instead of removing it - find the draft 
> text below. The draft was discussed in the Validation Working Group 
> meeting yesterday. We would like to offer this as an amendment to 
> Ballot
218.

Is it possible to provide a diff, e.g. by turning the new text into a Github 
pull request, or some other mechanism?

Once we have a diff, might it be possible for rationale to be provided for each 
change?

Gerv
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