Here is an attempt to address Apple’s comments during the voting.  This is 
based on discussions with Clint about how to resolve some of Apple’s concerns.  
Clint had some additional comments but I’ll let him provide those.

 

One of the biggest roadblocks is that Apple’s legal team has a problem with the 
rules about continuing to be a member of the working group, despite them being 
identical to the rules Apple is already subject to as part of the server 
certificate working group.  It’s not entirely clear to me what the concerns are 
yet, but I’d suggest it would be helpful to decouple that issue from the 
creation of the S/MIME working group.  I’m happy to discuss revisiting and 
revising those rules, but I think it should happen in a Forum-wide manner, and 
not hold up the S/MIME working group.

 

As always, very interested in hearing feedback from others who are looking to 
support the ballot.

 

-Tim

 

Explanation of changes inline with Apple’s voting comments:

 

There are a number of concerns with the version of the charter associated to 
this ballot. I regret, truly, that these issues weren’t all raised, nor 
addressed, prior to the voting period beginning, as I strongly support the 
basic intent of this ballot and hopefully future CWG. We, as an industry, need 
a consistent, auditable set of requirements against which S/MIME certificates 
can be issued and, when compliant, reliably and intercompatibly consumed by 
software providers. Email as a tool for the betterment of humankind has proven 
so effective as to be arguably invaluable; improving the security, privacy, and 
safety of using email is a very worthwhile goal which we unequivocally share 
with the ballot proposer and endorsers. Similarly, I do empathize with the 
impatience which is inevitably felt by those who have shepherded this document 
along these past years and would like to thank Dimitris for his helpful 
comments regarding the proposed changes, which I hope are addressed below.



Moving fast and breaking things is a mantra I can support in some low-risk, 
low-impact situations. The formation of such a pivotal working group is not one 
of them. Highlighted below are some high-level groupings of the concerns we 
have and to which we shared an updated draft proposal that addresses these same 
concerns.

*       Factual/technical inaccuracies

*       A private key associated with an S/MIME certificate is not used to 
encrypt emails; the public key is.

ACCEPT: Since the sentence is not intended to be technical, it is now more 
generic, and only talks about the key pair collectively being used to sign, 
encrypt, and decrypt emails.

*       An S/MIME certificate as defined solely through the presence of the 
emailProtection EKU does not, necessarily, have the capability of signing email 
(which is typically determined by a keyUsage OID).

REJECT: The fact that the EKU is necessary but not sufficient for email signing 
does not invalidate the charter’s use of the EKU to identity S/MIME 
certificates.  There are lots of things that can potentially prevent a 
certificate from being able to sign, encrypt or decrypt email, and it does not 
seem necessary to list all of them in a clause that is simply intended to draw 
a clear, bright line between certificates that are in scope for this working 
group, and certificates that are in scope for other working groups.  This 
matches existing practice for the code signing and server certificate working 
groups.

*       Grammatical corrections

*       “.... voting membership in the SMCWG must produce a develop and 
maintain....” is clearly simply a grammatical error. 
*       The numbering of charter sections is incorrect after #4.

ACCEPT.  It appears to be after section 5 where things go wrong.

*       Overemphasis on identity

*       This is understandably subjective, but I’m not sure the edits I 
proposed conveyed fully the concern. 
*       We have no objection to CAs including identity information in S/MIME 
certificates generally speaking, and believe the SMCWG to be the appropriate 
venue for establishing S/MIME certificate profiles including subject identity 
information. You can see subject identity information in the S/MIME certificate 
used to sign this email, just to provide a little good-faith evidence backing 
this statement (though it shouldn’t be necessary...).
*       What we do strongly object to is the potential for the working group to 
be sidelined into re-creation and bifurcation of identity validation processes. 
I don’t know the best way to express this in the charter (though I submitted my 
attempt) and that’s part of what I hoped discussion prior to voting to include, 
but I suppose this is an item where I’m simply “late to the party”.

PARTIALLY ACCEPTED: Identity is not overemphasized; indeed it is only mentioned 
at all to counter the assertions by some that it should not be discussed at 
all.  It should be noted that identity is NOT mentioned in the purpose of the 
ballot as an important priority, so it is already somewhat de-emphasized.  I 
added an exhortation to reuse existing identity work, even though this is 
always a best practice in standards work and shouldn’t need to be explicitly 
stated.  Note that the use cases for identities in S/MIME certificates are not 
entirely the same as for TLS certificates (e.g. individual identities are far 
more common), so some potential for divergence is inevitable.

I think it is fallacious to assert that preventing discussion of some topics 
will accelerate work on unrelated topics.  How rapidly work proceeds on any 
given topic will depend on the amount of time individual members are willing to 
commit to that topic, and their willingness to work together with others to 
bring the topic to a speedy resolution. 

*       Imprecise pronoun usage

*       “validate an email address and the subject’s identity prior to binding 
it to the email address” indicates the email address is bound to the email 
address? Or the subject’s identity is bound to the email address? 
*       I would posit this could instead be better categorized as a factual 
inaccuracy, assuming the intent was to convey the binding of (email address) || 
(email address && subject identity) to a public key in a certificate.

ACCEPT: It doesn’t appear to be a pronoun issue; that both are bound to the 
public key makes more sense.

*       Inconsistent incorporation of pre-existing and suitable reference work

*       In the closing paragraph of the Introduction section, it’s unclear why 
it’s appropriate to acknowledge existing methods for validating control of a 
domain, but not (in the same paragraph and context) acceptable to acknowledge 
existing methods for validating the identity of a subject. The conclusion this 
inconsistency points to for me is that the BRs and EVGs are insufficient to 
fully validate the identity of a subject. I believe this to be an erroneous 
conclusion, which I attempted to correct for with my proposed changes. 
*       If I’ve misunderstood and it is instead the position of the proposer 
that these other working group artifacts are indeed insufficient in 
representing “consistent and audited validation practices used by CAs in 
establishing the identity of a subject”, I think that would be incredibly 
useful to understand.

ACCEPT: Previous work on identity should also be mentioned.  It is up to the 
working group to decide whether this previous work is sufficient or not, and 
how it should be incorporated.

*       Automatic cessation of membership

*       The balloted wording around software update cadences introduces some 
precision/definition issues that would likely prove troublesome in and of 
themselves.
*       While some of those issues could be addressed through wordsmithing, the 
entire precept that membership may be automatically removed based on various 
conditions (both for Certificate Consumers and Issuers) is itself problematic 
and I think an area rife for improvement (both here and in other charters).

REJECT: The language is consistent with the language in the other working group 
charters.  Introducing new inconsistencies in this charter would be confusing 
for all involved.  If Apple believes these provisions are problematic, 
potential improvements should be discussed an applied across all chartered 
working groups.

*       Unnecessary augmentative stipulations

*       The statement “Verification of control over RFC822-compliant email 
addresses” fully encompasses the statement “Baseline verification of control 
over email addresses, including those used by a natural person or a legal 
entity, or used by automated systems such as for mailing lists”. In other 
words, the additional text following “including” is unnecessary and distracting 
to the primary scope as the text preceding “including” does not exclude natural 
persons, legal entities, nor automated systems.

*       One might mark this as a nit, and given discussion it’s almost 
certainly something that could be accepted as “Won’t Fix”, but the proposed 
change does improve the ballot and it does so without changing the actual scope 
or function of the working group.

REJECT: The language was intentionally added to address concerns from a 
potential certificate consumer that the provisions might be misinterpreted as 
not allowing addresses of mailing lists and other automated emails.

*       “even though they are managed by third-party service providers” seems 
to either intentionally introduce ambiguity around what’s truly out of scope 
(Is it “certs issued under a non-public root AND managed by a third-party 
service provider”?) or, hopefully more likely, simply attaches a clause to this 
scope item that neither adds clarity to nor detracts purpose from the intended 
scope (and should therefore be removed).

ACCEPT: This language is less helpful.

*       Overly broad scope

*       The inclusion of “Handling of messages during transport and on various 
mail user agents” is inappropriate for this forum. Handling of messages during 
transport is a matter of protocol specification, better suited to entities like 
the IETF. Handling of messages on various mail user agents is imprecise and 
therefore essentially meaningless, which is the opposite of what one would hope 
to find when defining the concrete, inclusive scope of a working group. Removal 
seemed the best option, as I haven’t seen any concrete representation of 
example work items related to this scope item.

ACCEPT: Though we may regret not including this, as modification of messages by 
MTAs and display of messages from legacy clients both are complicated issues, 
which sometimes interact with certificate profile considerations.  See recent 
header protection discussions on IETF LAMPS for more details.

*       Invalid membership requirements/processes

*       I think Ryan Sleevi has explained most of this better than I could, so 
I’ll refer to his message instead: 
https://cabforum.org/pipermail/public/2020-February/014874.html.
*       I looked, but failed to find information as to how mail transfer agents 
consume S/MIME certificates. However, since it’s included in the ballot I can 
only conclude that the proposer has relevant and detailed insight into how and 
why this is a valid categorization for Certificate Consumers and had hoped to 
be pointed to that information so as to better understand the scope of this 
proposed CWG.

REJECT: This was discussed extensively during the governance reform process, 
and the current procedures were deemed to be sufficient.  This charter simply 
follows those precedents.  Indeed, two other chartered working groups were 
successfully bootstrapped already.

Be well,

Clint

Attachment: SMIME Charter 2020-02-12.docx
Description: MS-Word 2007 document

Attachment: smime.p7s
Description: S/MIME cryptographic signature

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