> This raises a question about the MDSP policy and CAB Forum requirements. Who 
> is the subscriber in the reseller relation?  We believe this to be the key 
> holder. However, the language is unclear.

‘Subscriber’ is a defined term in the BRs:
Subscriber: A natural person or Legal Entity to whom a Certificate is issued 
and who is legally bound by a Subscriber Agreement or Terms of Use.

That’s pretty clear and can’t be stretched to cover a reseller—a reseller won’t 
be able to comply with a Subscriber Agreement.

> At this time, Trustico has not provided any information about how these 
> certificates were compromised or how they acquired the private keys.

One question I would have is whether Trustico is in compliance with 6.1.2, 
"Parties other than the Subscriber SHALL NOT archive the Subscriber Private Key 
without authorization by the Subscriber.”

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