On Sunday, 29 January 2017 02:28:53 UTC, Steve Medin  wrote:
> We completed our investigation of these 12 certificates by requesting
> archived documentation. CrossCert was unable to produce documentation to
> prove their validation as required under BR 5.4.1. We revoked all 12
> certificates within 24 hours of becoming aware of CrossCert's BR 5.4.1
> non-compliance. Our investigation continues.

Several of these certificates appear, on any surface inspection, to be 
legitimate certificates issued to real subscribers and yet presumably CrossCert 
was not able to document validation. So several thoughts arise, I appreciate 
that you might want to do more investigation before replying Steve, not least 
because there are quite a few questions here - and as always I welcome feedback 
from other participants meanwhile.

1. The six "false positive" certificates appear unremarkable except for the 
coincidence of including the word "test". If CrossCert can't produce 
documentation to show these were validated properly, it seems likely that many 
or even all certificates which Symantec had believed were validated by 
CrossCert in fact lack such documentation. Is that not so?

2. It had been my assumption, based on the CPS and other documents, that 
CrossCert was restricted in their use of Symantec's issuance function to C=KR, 
this is cold comfort for practical purposes in the Web PKI, but it would at 
least help us to scope any damage. The existence of certificates with C=BD in 
this list shows my assumption was wrong. How (if at all) can an outsider 
determine if in fact CrossCert caused issuance of a Symantec certificate ? 
Prior to Andrew's report what  _mechanical_ constraints on CrossCert's issuance 
were in place, in particular any beyond those which were applied to Symantec's 
own issuances? For example, would it have been possible for them to cause 
issuance of a 5-year cert? A SHA-1 certificate? To choose specific serial 
numbers?

3. Since we have every reason to imagine that some (or even all) of the 
affected certificates were issued in good faith to legitimate subscribers, it 
would have been nice for Symantec to alert the subscribers when their 
certificates were revoked. Did Symantec do this? If not does Symantec have the 
capability to contact these subscribers itself (e.g. email addresses, phone 
numbers)? If not, does Symantec contractually require of RA partners that they 
provide a capability for Symantec to contact their subscribers, or relay a 
message chosen by Symantec on their behalf ?

4. Although BR 5.4.1 says that these records are to be kept by the CA and each 
Delegated Third Party the obligation is on the CA (here, Symantec) to make the 
records available to their auditors. Is it in fact the case that this 
investigation is the first time Symantec has asked Crosscert for such records ? 
Wasn't Symantec concerned that KPMG (in a routine audit) might ask to see these 
records but they didn't have them ? Might not other RA partners be affected 
similarly ?

5. As Symantec will know from its own experience, audits have not proved to be 
sufficient for detecting systematic non-compliance by CAs. What measures 
_beyond_ the Webtrust audit did Symantec have in place to detect non-compliance 
by an RA partner ?
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