I agree with Andrew’s point, and I would also like to ask which type of 
certificates CommScope plans to issue in terms of key usage. The requested 
Roots are for TLS servers and clients. Will you be a TLS Client 
Certificate-heavy CA, or will you issue mostly Server certificates?

Do you plan to offer certificates to other entities or will you only be issuing 
certificates for your own products?

I read your post carefully about the value to the ecosystem stemming from your 
experience, but I did not understand what the difference will be at the 
certificate layer, and why a publicly trusted Root CA is needed to serve this.

You write:

> CommScope is more than just a standard CA. With its wealth of experience 
> dealing with device manufacturing, deployment and operation, we are also well 
> positioned to serve device manufacturers and operators of device fleets, 
> whose requirements are not the same as typical web site operators.

Based on that, I wanted to ask: have you tried (or plan to use) ACME for these 
types of operations? If not, what is preventing you from doing so?

The WebPKI has evolved to serve website operators, and the vast amount of 
requirements imposed on all of its CAs have been designed for browsers and 
websites, so you may have to face challenging circumstances if you try to 
deviate too far from that. Especially with IoT, where — as Andrew said — 
revocation and renewal is difficult, especially at these volumes you describe, 
every incident that occurs will be more difficult to deal with, not just for 
CommScope, but potentially for other entities involved such as user agents. CAs 
are also required to implement changes relatively quickly. The typical time 
frame is either weeks or months. Does that match your expectations and the 
lifecycle for software updates and changes to your relying parties?

It’s not clear to me what the purpose of this application is, but perhaps you 
are limiting your flexibility quite a bit by going down that path. I’m not 
saying you should, or shouldn’t, I just want to understand if this is all clear 
from the beginning. You clearly have experience with PKIs, so I just wanted to 
get your thoughts on the issues above.

Thanks,
Antonis 

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