Re: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Matt Palmer via dev-security-policy
On Mon, Mar 23, 2020 at 06:15:00PM +, Jeremy Rowley wrote:
> There are two things worth discussing in general:
> 
> 1. I’m very interested in seeing the Let’s Encrypt response to this issue
> since the biggest obstacle in trying to find all of the keys with the same
> private key is the sheer volume of the certs.  Trying to do a
> comprehensive search when a private key is provided leaves some window
> between when we start the analysis and when we revoke.

Well, Let's Encrypt has committed to automatically blacklisting keys
reported for keyCompromise in its CA software
(https://community.letsencrypt.org/t/116762), so it won't be nearly as
problematic for them as it appears to be for Digicert.  At any rate, though,
I can get a list of all certs with a certain SPKI out of crt.sh in a matter
of a couple of seconds, and crt.sh has a *lot* more certs in it than
Digicert has issued.  The schema for the certwatch database is publicly
available, so, if nothing else, you could stand up a copy of that database,
skip deploying the CT scrapers, and just stuff a copy of every cert you
issue into the certificate table, and you're off to the races.

> 1. Another issue in trying to report keys that aren’t affiliated with
> any cert is that the process becomes subject to abuse.  Without knowing a
> cert affiliated with a key, someone can continuously generate keys and
> submit them as compromised.  You end up just blacklisting random keys,
> DDOSing the revocation system as it kicks off another request to  search
> for those keys.  I don’t think it’s feasible.  This is why the disclosures
> need to be affiliated with actual certs.

I don't think that anyone has, as yet, claimed that it is a BR violation for
a CA to issue a certificate with a key for which they have not yet received
a valid certificate problem report.  Nor do I believe that anyone has
claimed that a certificate problem report without any indication of a
problematic certificate is valid.  So, it appears to me that you're arguing
against something that nobody has proposed.

- Matt

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Re: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Matt Palmer via dev-security-policy
On Mon, Mar 23, 2020 at 12:53:43PM -0400, Ryan Sleevi wrote:
> To make sure I understand the timeline correctly:
> 2020-03-20 02:05:49 UTC - Matt reports SPKI 4310b6bc0841efd7fcec6ba0ed1f36
> e7a28bf9a707ae7f7771e2cd4b6f31b5af, associated with
> https://crt.sh/?id=1760024320 , as compromised
> 2020-03-21 01:56:31 UTC - DigiCert issues https://crt.sh/?id=2606438724 with
> that same SPKI
> 2020-03-21 02:09:12 UTC - DigiCert revokes https://crt.sh/?id=1760024320
> 2020-03-23 03:16:18 UTC - DigiCert revokes https://crt.sh/?id=2606438724
> 
> Is that roughly correct?

Yes, that appears to be a correct summary of the timeline as I see it.

- Matt

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Re: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Matt Palmer via dev-security-policy
On Mon, Mar 23, 2020 at 03:01:34PM +, Jeremy Rowley wrote:
> Ryan's post was the part I thought was relevant, but I understood it
> differently.  The cert was issued, but we should have now revoked it (24
> hours after receiving notice).  I do see your interpretation though, and
> the language does support 24 hours after issuing the new cert.

Aha, righto.  Glad we've gotten on the same page there.

> What I need is a tool that scans after revocation to ensure there are no
> additional certs with the same key.

I can give you a certwatch SQL query that'll do that, if you like -- "show
me all certs with this SPKI (or set of SPKIs) which aren't expired or
OCSP-revoked".  I use pretty much that query to get periodic reports of new
certificates that have appeared with keys already in the dungeon.  It's not
ideal for your purposes, though -- you might get some false positives
because your OCSP responders aren't up-to-date, and false negatives are
possible if certwatch is backlogged (or a cert wasn't logged).

Beyond that, though, if your internal certificate archive isn't indexed on
SPKI fingerprint, and updated in near-real-time, those are problems that I
think you'll have to fix, because the Internet's propensity to post their
private keys on the Internet, and then reuse them to get new certs after the
old one got revoked for key compromise, does not seem to be one that is
going away any time soon.

> The frustration is that this was
> where the cert was issued after our scan of all keys but just before
> revocation.  As a side note, our system blacklists the keys when a cert is
> revoked for key compromise, which means I don't have a way to blacklist a
> key before a cert is ever issued.

To the software developers!  *blows trumpets*

> >> I don't think that supports your point, though, so I wonder if I've got
> >> the wrong part.  That last part of Ryan's: "shenanigans, such as CAs
> >> arguing the[y?] require per-cert evidence rather than systemic
> >> demonstrations", seems to me like it's describing your statement,
> >> above, that you (only?) "need to revoke a cert that is key compromised
> >> once we're the key is compromised *for that cert*" (emphasis added).  I
> >> don't read Ryan's use of "shenanigans" as approving of that sort of
> >> thing.
> 
> I don't think its shenanigans, but I do think it's a pretty common
> interpretation.  Such information would help determine the common
> interpretation of this section.  I agree that CAs should scan all certs
> for the same key and revoke where they find them.  Is that actually
> happening?

A lot to unpack here, let me make up some specific questions and answer them
as best I can.

"Have any other CAs failed to revoke certificates issued for keys for
which they had previously revoked a certificate for key compromise?"

Yes, one CA has failed to do so, and I've reported that to this list.

"Have any other CAs successfully revoked a certificate within the
BR-mandated (am I OK using that phrase now?) time period, that they issued
for a private key for which they had previously revoked a certificate due to
key compromise?"

I don't know, I haven't checked (yet).  It's on my (lengthy) list of Interesting
Questions For Which I Need To Write Insanely Complicated SQL Queries.

"Have any other CAs blacklisted a private key that was reported as
compromised and prevented issuance before they had issued a certificate for
that key?"

Naturally I can't answer that one directly, because I don't have internal
access to CA systems.  *But*, I have one test case, in which a private key
known to have "hopped" between CAs after revocation was reported to a number
of CAs proactively, but there hasn't been a resolution to that test case one
way or the other.  No new certs have been issued for the same name, with the
compromised key or any other, so it's impossible to infer what the outcome
may be.

Other very specific questions welcomed.  The answers will probably be "I
haven't looked yet", but there are a lot of questions I've got at least a
vague idea of how to answer, once I have time2SQL.

> Do other CAs object to there being a lack of specificity if you give the
> keys without a cert attached?

Since I have been sending (links to) CSR format compromise attestations, no
CA has communicated an objection to the format of my reports, nor have they
failed to act (in some fashion) to any of my reports, as far as I am aware.

> >> Bim bam bom, all done and dusted, and we can get back to washing our 
> >> hands. 
>
> That you're *not* doing that is perplexing, and a little disconcerting.

My wife is immuno-suppressed -- about the only time I'm not washing my
hands is when I'm typing at my keyboard (the suds get in the switches and
cause all sorts of problems).  If I could get a reliable supply of
sanitizer, I'd be swimming in the stuff.

> That's an oversimplification of the incident report process.  I'm not
> resisting the incident report itself since incident reports are a 

RE: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Jeremy Rowley via dev-security-policy
Yeah  - that’s about the sum of it. I’ll file an incident report.

There are two things worth discussing in general:

  1.  I’m very interested in seeing the Let’s Encrypt response to this issue 
since the biggest obstacle in trying to find all of the keys with the same 
private key is the sheer volume of the certs. Trying to do a comprehensive 
search when a private key is provided leaves some window between when we start 
the analysis and when we revoke.


  1.  Another issue in trying to report keys that aren’t affiliated with any 
cert is that the process becomes subject to abuse. Without knowing a cert 
affiliated with a key, someone can continuously generate keys and submit them 
as compromised. You end up just blacklisting random keys, DDOSing the 
revocation system as it kicks off another request to  search for those keys.  I 
don’t think it’s feasible. This is why the disclosures need to be affiliated 
with actual certs.




From: Ryan Sleevi 
Sent: Monday, March 23, 2020 10:54 AM
To: Jeremy Rowley 
Cc: Matt Palmer ; Mozilla 

Subject: Re: Digicert: failure to revoke certificate with previously 
compromised key



On Mon, Mar 23, 2020 at 11:01 AM Jeremy Rowley via dev-security-policy 
mailto:dev-security-policy@lists.mozilla.org>>
 wrote:
Hey Matt,

Ryan's post was the part I thought was relevant, but I understood it 
differently. The cert was issued, but we should have now revoked it (24 hours 
after receiving notice). I do see your interpretation though, and the language 
does support 24 hours after issuing the new cert.  What I need is a tool that 
scans after revocation to ensure there are no additional certs with the same 
key.  The frustration is that this was where the cert was issued after our scan 
of all keys but just before revocation.  As a side note, our system blacklists 
the keys when a cert is revoked for key compromise, which means I don't have a 
way to blacklist a key before a cert is ever issued.

Matt, Jeremy,

To make sure I understand the timeline correctly:
2020-03-20 02:05:49 UTC - Matt reports SPKI 
4310b6bc0841efd7fcec6ba0ed1f36e7a28bf9a707ae7f7771e2cd4b6f31b5af, associated 
with https://crt.sh/?id=1760024320 , as compromised
2020-03-21 01:56:31 UTC - DigiCert issues https://crt.sh/?id=2606438724 with 
that same SPKI
2020-03-21 02:09:12 UTC - DigiCert revokes https://crt.sh/?id=1760024320
2020-03-23 03:16:18 UTC - DigiCert revokes https://crt.sh/?id=2606438724

Is that roughly correct?

If so, it does seem like an Incident Report is warranted here, so we can 
understand why:
a) https://crt.sh/?id=2606438724 wasn't revoked when 
https://crt.sh/?id=1760024320 was revoked (assuming those timestamps in the CRL 
are accurate)
b) The key wasn't blocklisted as known compromised (if the timestamps are 
incorrect)

That is, it doesn't seem unreasonable that, for situations of key compromise, 
the CA has the necessary data to scan their systems for potential reuse of that 
key. Given DigiCert's data 
lake<https://bugzilla.mozilla.org/show_bug.cgi?id=1526154>, it should be 
possible to scan for issues.

If I've misunderstood the timing here, please feel free to correct. This is 
where the incident report process is useful, and Resolved/Invalid is a 
perfectly fine state to end in.
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Re: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Ryan Sleevi via dev-security-policy
On Mon, Mar 23, 2020 at 11:01 AM Jeremy Rowley via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> Hey Matt,
>
> Ryan's post was the part I thought was relevant, but I understood it
> differently. The cert was issued, but we should have now revoked it (24
> hours after receiving notice). I do see your interpretation though, and the
> language does support 24 hours after issuing the new cert.  What I need is
> a tool that scans after revocation to ensure there are no additional certs
> with the same key.  The frustration is that this was where the cert was
> issued after our scan of all keys but just before revocation.  As a side
> note, our system blacklists the keys when a cert is revoked for key
> compromise, which means I don't have a way to blacklist a key before a cert
> is ever issued.
>

Matt, Jeremy,

To make sure I understand the timeline correctly:
2020-03-20 02:05:49 UTC - Matt reports SPKI 4310b6bc0841efd7fcec6ba0ed1f36
e7a28bf9a707ae7f7771e2cd4b6f31b5af, associated with
https://crt.sh/?id=1760024320 , as compromised
2020-03-21 01:56:31 UTC - DigiCert issues https://crt.sh/?id=2606438724 with
that same SPKI
2020-03-21 02:09:12 UTC - DigiCert revokes https://crt.sh/?id=1760024320
2020-03-23 03:16:18 UTC - DigiCert revokes https://crt.sh/?id=2606438724

Is that roughly correct?

If so, it does seem like an Incident Report is warranted here, so we can
understand why:
a) https://crt.sh/?id=2606438724 wasn't revoked when
https://crt.sh/?id=1760024320 was revoked (assuming those timestamps in the
CRL are accurate)
b) The key wasn't blocklisted as known compromised (if the timestamps are
incorrect)

That is, it doesn't seem unreasonable that, for situations of key
compromise, the CA has the necessary data to scan their systems for
potential reuse of that key. Given DigiCert's data lake
, it should be
possible to scan for issues.

If I've misunderstood the timing here, please feel free to correct. This is
where the incident report process is useful, and Resolved/Invalid is a
perfectly fine state to end in.
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RE: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Jeremy Rowley via dev-security-policy
iguity in 
the CAB forum would be good.  As you pointed out "obtains" can mean different 
things. 

>> The time to say "hey, while we *can* process these SPKIs and CSRs, they are 
>> kinda teh suck, what else you got?" would have been, ideally, when I sent 
>> that first trickle of compromise reports that were acted upon.  At worst, 
>> when the Big Bomb of Keys dropped, you stick your hand up and say "uhm, 
>> these kinda suck to process, any chance it's easy for you to send us X 
>> instead?", while simultaneously working on the pile as best you can.  Worst 
>> case I've gone to bed, and you do what you did anyway, but depending on what 
>> X was, I might have been able to oblige.

To be clear, I'm not complaining about the format. I'm wondering when we 
obtained the private key for the 24 hour purposes. With automation, the time 
between when we get the email and when we confirm key compromise should be 
nearly zero. However, with a more manual process, that time is not 
insignificant. What I don't like about the interpretation that  the revocation 
event is 24 hours from when we get an email is some emails are very vague about 
key compromise.  With that reading, if we get an email without proof that is 
later followed up by proof, the 24 hour period could start when we get the 
initial email even if the proof is provided 25 hours later.  That does happen, 
which is why I think the time period should be 24 hours from after the CA 
receives proof of key compromise. But even that is ambiguous. When did we 
receive proof of key compromise? I'd say it's when all the CSRs finished 
downloading. If that's not the case, then you are encouraging CAs to be myopic 
in the way they accept key compromise information.

Jeremy


-Original Message-
From: dev-security-policy  On 
Behalf Of Matt Palmer via dev-security-policy
Sent: Monday, March 23, 2020 4:45 AM
To: Mozilla 
Subject: Re: Digicert: failure to revoke certificate with previously 
compromised key

On Mon, Mar 23, 2020 at 06:14:29AM +, Jeremy Rowley wrote:
> That's not the visible consensus IMO.  The visible consensus is we 
> need to revoke a cert that is key compromised once we're informed the 
> key is compromised for that cert 
> (https://groups.google.com/forum/m/#!topic/mozilla.dev.security.policy/1ftkqbsnEU4).

I think that link might not be doing what you expect, as it (at least for
me) is collapsing all the replies in that topic before Doug Beattie's post. 
The only response that seems relevant in that topic to was Ryan's reply to me 
up-thread from Doug's post, which was, in (I believe) relevant part, when I 
asked the question:

> 3. Can a CA be deemed to have "obtained evidence" of key compromise prior 
>to the issuance of a certificate, via a previously-submitted key
>compromise problem report for the same private key?  If so, it would
>seem that, even if the issuance of the certificate is OK, it is a
>failure-to-revoke incident if the cert doesn't get revoked within 24
>hours...

To which Ryan replied:

> Correct, that was indeed the previous conclusion around this. The CA 
> can issue, but then are obligated to revoke within 24 hours. There’s 
> not a statute of limitation on “obtains evidence” here, precisely 
> because it could allow a host of shenanigans, such as CAs arguing the 
> require per-cert evidence rather than systemic demonstrations.

I don't think that supports your point, though, so I wonder if I've got the 
wrong part.  That last part of Ryan's: "shenanigans, such as CAs arguing 
the[y?] require per-cert evidence rather than systemic demonstrations", seems 
to me like it's describing your statement, above, that you (only?) "need to 
revoke a cert that is key compromised once we're the key is compromised *for 
that cert*" (emphasis added).  I don't read Ryan's use of "shenanigans" as 
approving of that sort of thing.

> The certificate you mentioned was issued before the keys were 
> blacklisted and not part of a certificate problem report.  When 
> revoking a cert we scan to see if additional certs are issued with the 
> same key t, but this particular cert one was issued after the scan but 
> before the revocation, largely because the way you are submitting 
> certificate problem reports breaks automation.  We currently don't 
> have a way to blacklist private keys until a certificate is revoked, 
> although that would be a nice enhancement for us to add in the future.  
> Anyway, I don't think anything reported violated the  BR since 1) this 
> cert was not part of a certificate problem report and 2) we will be 
> revoking within 24 hours of your Mozilla posting.

The way I see it, once a CA is provided with accepted evidence of key 
compromise, every certificate issued by that CA using the same key 

Re: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Matt Palmer via dev-security-policy
On Mon, Mar 23, 2020 at 06:14:29AM +, Jeremy Rowley wrote:
> That's not the visible consensus IMO.  The visible consensus is we need to
> revoke a cert that is key compromised once we're informed the key is
> compromised for that cert
> (https://groups.google.com/forum/m/#!topic/mozilla.dev.security.policy/1ftkqbsnEU4).
>  

I think that link might not be doing what you expect, as it (at least for
me) is collapsing all the replies in that topic before Doug Beattie's post. 
The only response that seems relevant in that topic to was Ryan's reply to
me up-thread from Doug's post, which was, in (I believe) relevant part, when
I asked the question:

> 3. Can a CA be deemed to have "obtained evidence" of key compromise prior 
>to the issuance of a certificate, via a previously-submitted key
>compromise problem report for the same private key?  If so, it would
>seem that, even if the issuance of the certificate is OK, it is a
>failure-to-revoke incident if the cert doesn't get revoked within 24
>hours...

To which Ryan replied:

> Correct, that was indeed the previous conclusion around this. The CA can 
> issue, but then are obligated to revoke within 24 hours. There’s not a 
> statute of limitation on “obtains evidence” here, precisely because it 
> could allow a host of shenanigans, such as CAs arguing the require per-cert 
> evidence rather than systemic demonstrations. 

I don't think that supports your point, though, so I wonder if I've got the
wrong part.  That last part of Ryan's: "shenanigans, such as CAs arguing
the[y?] require per-cert evidence rather than systemic demonstrations",
seems to me like it's describing your statement, above, that you (only?)
"need to revoke a cert that is key compromised once we're the key is
compromised *for that cert*" (emphasis added).  I don't read Ryan's use of
"shenanigans" as approving of that sort of thing.

> The certificate you mentioned was issued before the keys were blacklisted
> and not part of a certificate problem report.  When revoking a cert we
> scan to see if additional certs are issued with the same key t, but this
> particular cert one was issued after the scan but before the revocation,
> largely because the way you are submitting certificate problem reports
> breaks automation.  We currently don't have a way to blacklist private
> keys until a certificate is revoked, although that would be a nice
> enhancement for us to add in the future.  Anyway, I don't think anything
> reported violated the  BR since 1) this cert was not part of a certificate
> problem report and 2) we will be revoking within 24 hours of your Mozilla
> posting.

The way I see it, once a CA is provided with accepted evidence of key
compromise, every certificate issued by that CA using the same key -- past,
present, and future -- is implicitly part of that certificate problem
report.  *I* think that's supported by Ryan's confirmation of my question,
quoted above, but presumably you disagree?

At the end of the day the only call that matters is that of the CA module
owner and peers, so I guess we'll have to leave it up to them to make the
call as to whether Digicert's behaviour that I described -- and the facts of
which you don't seem to dispute -- constitutes a BR violation.

Honestly, I'm a bit surprised you're trying so hard to argue against taking
responsibility for this occurrence (probably should use "incident" yet, I
guess).  Based on purely on what you wrote in the above paragraph, it seems
like it was a simple oversight in your systems for what is, I won't deny, a
bit of a corner case.  Even I, as gung-ho as I am about throwing out
misbehaving CAs, wouldn't argue that this in and of itself is anything worth
a rap over the knuckles for.

As far as I can see, the meat of an incident report for this occurrence
could be something like "our key blacklist is only populated at the time
revocation occurs; the certificate in question was issued between problem
report and revocation; we've added a story to the backlog to modify our CA
systems to allow keys to be blacklisted before revocation, and until then
we've modified our procedures to do a sweep of our certificate archive after
the initial revocation has taken place, to catch a similarly situated
certificate in the future."

Bim bam bom, all done and dusted, and we can get back to washing our hands. 
That you're *not* doing that is perplexing, and a little disconcerting.

> I support the idea of swift revocation of compromised private keys and do
> appreciate you reporting them.  I think this is helpful in ensuring the
> safety of users online.  However, using the SPKI to submit information
> breaks our automation, making finding and revoking certs difficult.  The
> more standards way (IMO) is the SHA2 thumbprint or serial number or a good
> old CSR.

This confuses me a bit; an SPKI *is* a "SHA2[56] thumbprint" of the
compromised key, and keys don't have serial numbers.  As for a CSR, I
provide one, signed 

RE: Digicert: failure to revoke certificate with previously compromised key

2020-03-23 Thread Jeremy Rowley via dev-security-policy
That's not the visible consensus IMO. The visible consensus is we need to 
revoke a cert that is key compromised once we're informed the key is 
compromised for that cert 
(https://groups.google.com/forum/m/#!topic/mozilla.dev.security.policy/1ftkqbsnEU4).
 The certificate you mentioned was issued before the keys were blacklisted and 
not part of a certificate problem report.  When revoking a cert we scan to see 
if additional certs are issued with the same key t, but this particular cert 
one was issued after the scan but before the revocation, largely because the 
way you are submitting certificate problem reports breaks automation. We 
currently don't have a way to blacklist private keys until a certificate is 
revoked, although that would be a nice enhancement for us to add in the future. 
 Anyway, I don't think anything reported violated the  BR since 1) this cert 
was not part of a certificate problem report and 2) we will be revoking within 
24 hours of your Mozilla posting. 

I support the idea of swift revocation of compromised private keys and do 
appreciate you reporting them. I think this is helpful in ensuring the safety 
of users online. However, using the SPKI to submit information breaks our 
automation, making finding and revoking certs difficult. The more standards way 
(IMO) is the SHA2 thumbprint or serial number or a good old CSR.  Because 
submitting the SPKI breaks automation, getting evidence of key compromise took 
an additional 5 hours after you submitted the report. We still revoked all of 
the current certs with submitted keys within 24 hours of the report (since 
compromised private keys are bad and there is nothing that says we can't revoke 
earlier than 24 hours), but I did want to clarify that I don't think the time 
starts until we can actually get the information necessary to do an 
investigation (because there is not sufficient evidence of a key compromise 
until then). 

Going to the previous discussion, I'd definitely support seeing a standardized 
way to report key compromise. Trying to account for the various formats they 
come in and through the various channels creates a lot of manual work on a 
process that can easily be automated. 

Jeremy


-Original Message-
From: dev-security-policy  On 
Behalf Of Matt Palmer via dev-security-policy
Sent: Saturday, March 21, 2020 11:01 PM
To: Mozilla 
Subject: Digicert: failure to revoke certificate with previously compromised key

Certificate https://crt.sh/?id=2606438724, issued either at 2020-03-21
00:00:00 UTC (going by notBefore) or 2020-03-21 01:56:31 UTC (going by SCTs), 
is using a private key with SPKI 
4310b6bc0841efd7fcec6ba0ed1f36e7a28bf9a707ae7f7771e2cd4b6f31b5af, which was 
reported to Digicert as compromised on 2020-03-20 02:05:49 UTC (and for which 
https://crt.sh/?id=1760024320 was revoked for keyCompromise soon after 
certificate 2606438724 was issued).

As previously discussed on this list, the visible consensus is that, according 
to the BRs, certificates for which the CA already had evidence of key 
compromise must be revoked within 24 hours of issuance.  That 24 hour period 
has passed for the above certificate, and thus it would appear that Digicert 
has failed to abide by the BRs.

- Matt

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Digicert: failure to revoke certificate with previously compromised key

2020-03-21 Thread Matt Palmer via dev-security-policy
Certificate https://crt.sh/?id=2606438724, issued either at 2020-03-21
00:00:00 UTC (going by notBefore) or 2020-03-21 01:56:31 UTC (going by
SCTs), is using a private key with SPKI
4310b6bc0841efd7fcec6ba0ed1f36e7a28bf9a707ae7f7771e2cd4b6f31b5af, which was
reported to Digicert as compromised on 2020-03-20 02:05:49 UTC (and for
which https://crt.sh/?id=1760024320 was revoked for keyCompromise soon after
certificate 2606438724 was issued).

As previously discussed on this list, the visible consensus is that,
according to the BRs, certificates for which the CA already had evidence of
key compromise must be revoked within 24 hours of issuance.  That 24 hour
period has passed for the above certificate, and thus it would appear that
Digicert has failed to abide by the BRs.

- Matt

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