Re: dropping the root is useless

2008-12-29 Thread Kyle Hamilton
Uhm...

how did you arrive at the tens of thousands of other Comodo
customers figure?  I don't believe that Comodo has disclosed the
number of unique domain names served by certificates that it has
issued.

And since the number one reason for having a CA in the root list is
for Mozilla-software user security, how do you arrive at punish [...]
millions of users?

TLS is geared very obviously toward security-of-the-user (among other
things, a server that does not provide a certificate cannot ask for
client authentication), and the user is who we're trying to protect
(since the user is the one who interacts with Mozilla apps) -- NOT the
server.

As far as I can tell, there is no easy way for users to self-identify
whether the web sites that they're going to are using Comodo
certificates.  As far as I can tell, there is no reporting of what CAs
are used by sites browsed to by any given installation of Mozilla
software.

This leads me to believe that there are three possibilities:

1) You have communication from Robin about the number of certificates
that Comodo has issued that the rest of us are not privy to, OR
2) You have some way of knowing what CAs are in use by the servers
that users of the Mozilla applications use (which concept rather
scares me, since it hasn't been disclosed as part of the software
operations), OR
3) You're pulling numbers out of thin air.

-Kyle H

On Sun, Dec 28, 2008 at 11:41 PM, Grey Hodge g...@burntelectrons.org wrote:
 On 12/28/2008 9:42 AM Eddy Nigg cranked up the brainbox and said:
 On 12/28/2008 04:24 PM, Ian G:
 No, I'm afraid there is an agreement to list the root, under a policy.
 Once listed, Mozilla has to operate according to its side of the bargain.
 Apparently you are reading something I haven't.

 Apparently, but that doesn't mean it's invalid. Mozilla can't act arbitrarily
 and without cause and expect to retain any shred of respect or
 trustworthiness. A policy not adhered to is worthless.

 That's for the specific certstar case. Domain validation isn't performed
 by Comodo on a wide scale apparently and perhaps no validation is
 performed at all.

 Yes, perhaps, and perhaps they send out certs to anyone who asks nicely, but
 we have little evidence to support these suppositions.

 Rather than having a kneejerk reaction of removing Comodo from the root list,
 why don't we examine the situation. This reseller was not acting according to
 proper procedure. Comodo immediately revoked their reseller status, and
 reviewed their certs. Further, they've said they're reviewing their policies
 to ensure this doesn't happen again. Given their candor and quick response,
 what more do you require that you feel you're not getting that justified
 removing them as a root CA?

 I really think you're going overboard. Form what I see, I'm not alone in that
 assessment. You did a good job in bringing this to light. Having the issues
 you uncovered addressed and fixed should be sufficient. Why do we need to take
 punitive action that will do nothing but punish tens of thousands of other
 Comodo customers and millions of users?

 --
 Grey Hodge
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Re: dropping the root is useless

2008-12-29 Thread Ian G

On 29/12/08 09:47, Kyle Hamilton wrote:

Uhm...

how did you arrive at the tens of thousands of other Comodo
customers figure?  I don't believe that Comodo has disclosed the
number of unique domain names served by certificates that it has
issued.



http://www.securityspace.com/s_survey/sdata/200611/certca.html

Security Space figures are now sold not openly published, that is 2 
years old.  To save the click, December 2006, Security Space reports 
that Comodo had 13,715 certs in live.


1.  I'll leave to others to address the various fudge factors.
2.  If anyone has any view on a new, current report, they could help 
reduce the FUD by letting us know that CA's current numbers.




And since the number one reason for having a CA in the root list is
for Mozilla-software user security, how do you arrive at punish [...]
millions of users?



In my earlier post, I took the certs and multiplied by 100.  It's a 
finger in the air, a hand waving.  I have no idea, but it is probably 
more than 10.  If it was 10, the server would likely go for a SSC.  :)




2) You have some way of knowing what CAs are in use by the servers
that users of the Mozilla applications use (which concept rather
scares me, since it hasn't been disclosed as part of the software
operations), OR


As above.


3) You're pulling numbers out of thin air.


Yes, start with what we know.  13,715 two years back.  Then add some 
estimates of what we don't know.  Call it 20k now.  Multiply by 100 
users to get 2m.


The number at the end is flaky, but it is better than no number.  Refine 
as more info comes to hand.


iang
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Re: dropping the root is useless

2008-12-29 Thread Eddy Nigg

On 12/29/2008 09:41 AM, Grey Hodge:


Apparently, but that doesn't mean it's invalid. Mozilla can't act arbitrarily
and without cause and expect to retain any shred of respect or
trustworthiness.


Nobody suggested that I think. There is however real cause for concern.



Yes, perhaps, and perhaps they send out certs to anyone who asks nicely, but
we have little evidence to support these suppositions.


Please read the other thread Facts about Comodo Resellers and RAs at 
http://groups.google.com/group/mozilla.dev.tech.crypto/browse_thread/thread/e2755401a7dec203


Please do not add comments to that thread without relevance, thanks.



Rather than having a kneejerk reaction of removing Comodo from the root list,
why don't we examine the situation. This reseller was not acting according to
proper procedure. Comodo immediately revoked their reseller status, and
reviewed their certs. Further, they've said they're reviewing their policies
to ensure this doesn't happen again. Given their candor and quick response,
what more do you require that you feel you're not getting that justified
removing them as a root CA?

I really think you're going overboard. Form what I see, I'm not alone in that
assessment. You did a good job in bringing this to light. Having the issues
you uncovered addressed and fixed should be sufficient. Why do we need to take
punitive action that will do nothing but punish tens of thousands of other
Comodo customers and millions of users?




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Re: dropping the root is useless

2008-12-29 Thread Eddy Nigg

On 12/29/2008 07:40 AM, David E. Ross:

On 12/28/2008 3:45 PM, Kyle Hamilton wrote [in part]:

CertStar was found out, only due to the diligence of someone on this
list.  How many other RAs haven't been found out yet?  We can't know,
because Comodo won't say.  This affects the confidence I have in their
system (i.e., it removes ALL confidence that Mozilla extended on my
behalf).


Actually, Eddy discovered the problem only through the fortuitous
receipt of spam from CertStar.  If he had not received the spam -- even
if others had received it -- it is possible the problem would never have
been discovered.  This is why the discovery is so frightening.


I will suggest that Mozilla allocate some funds for random checking of 
the performance of CAs.




Now that it is known that a subordinate reseller operating under one CA
issued certificates without authenticating the identity of the
subscribers, we know that the theoretical concern expressed (before all
this) about resellers is no longer theoretical.  NOW is the time to
require that all CAs supervise the operations of their RAs and
resellers.  This must be done in a way that independent audits of the
CAs examine the implementation of such supervision, which can be
accomplished by requiring (at least with respect to the Mozilla
database) that CPs explicitly address how that supervision is performed.

Either a CA's CP must explicitly state that there are NO external RAs or
resellers, or else the CP must describe how external subordinates are
monitored.  Without this, a CA's request to have its root certificate
included in the Mozilla database should be denied.  Since an audit will
generally report on the implementation of such a policy but not
necessarily on the policy's adequacy, the internal and public reviews of
CA requests must examine the adequacy of the CA's policy for monitoring
external subordinates.



+1


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Re: dropping the root is useless

2008-12-29 Thread Grey Hodge
On 12/29/2008 3:47 AM Kyle Hamilton cranked up the brainbox and said:
 And since the number one reason for having a CA in the root list is
 for Mozilla-software user security, how do you arrive at punish [...]
 millions of users?

If all of Comodo's certs cease to be trusted, millions of web surfers will see
errors on potentially thousands of sites.

 This leads me to believe that there are three possibilities:
 1) You have communication from Robin about the number of certificates
 that Comodo has issued that the rest of us are not privy to, OR
 2) You have some way of knowing what CAs are in use by the servers
 that users of the Mozilla applications use (which concept rather
 scares me, since it hasn't been disclosed as part of the software
 operations), OR

The fact you think these are even reasonably conclusions tells me a lot about
your reasoning skills.

 3) You're pulling numbers out of thin air.

Indeed, I am, as an educated guess. Comodo is a root CA. You don't get root
status by having a handful of customers. It's hard business to break into, and
Comodo has been around a while. I find it hard to believe a company of their
size and age has any fewer than ten thousand certs out there, and that's a
lowball guess. There are many hundreds of millions of web users, and millions
of websites. Do you really find it hard to believe at least 1% of those secure
sites might be using a Comodo cert?

-- 
Grey Hodge
 email [ grey @ burntelectrons.org ]
 web   [ http://burntelectrons.org ]
 tag   [ Don't touch that! You might mutate your fingers! ]
 motto [ Make everything as simple as possible, but no simpler. - Einstein ]
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Re: dropping the root is useless

2008-12-29 Thread Grey Hodge
On 12/29/2008 8:45 AM Eddy Nigg cranked up the brainbox and said:
 Please do not add comments to that thread without relevance, thanks.

Excuse me, I've had enough or your arrogant attitude. I've seen the way you've
been treating people and I can name half a dozen off the top of my head you've
been rude to. Knock it off, you're not in any position to tell anyone where to
post and not to post. Further, I've been following the threads for a while
now, thank you very much. I'll thank you to treat people with more respect or
kindly shove off. You did a good deed unveiling Certstar, don't blow that good
will with obnoxiousness.

-- 
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 email [ grey @ burntelectrons.org ]
 web   [ http://burntelectrons.org ]
 tag   [ Don't touch that! You might mutate your fingers! ]
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Re: dropping the root is useless

2008-12-29 Thread Eddy Nigg

On 12/29/2008 10:23 PM, Grey Hodge:

Indeed, I am, as an educated guess. Comodo is a root CA. You don't get root
status by having a handful of customers.


The amount of customers never was a known criteria of CAs business 
practices ever.



It's hard business to break into, and
Comodo has been around a while. I find it hard to believe a company of their
size and age has any fewer than ten thousand certs out there, and that's a
lowball guess. There are many hundreds of millions of web users, and millions
of websites.


Isn't the responsibility of a CA this size much greater and breach of 
trust going to affect many? Is a breach of trust justified and 
acceptable because of the size of a CA or shouldn't that CA provide 
extra care?


(For your knowledge, Netcraft confirms these days about one million 
secured web sites altogether, 10-15 percent belonging to Comodo I think, 
which is of course still a lot. But it's not millions of web sites. 
Additionally Comodo has many different roots and as I understood from 
Kyle, he suggested to look at the affected ones.)


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Re: dropping the root is useless

2008-12-29 Thread David E. Ross
On 12/29/2008 12:23 PM, Grey Hodge wrote:
 On 12/29/2008 3:47 AM Kyle Hamilton cranked up the brainbox and said:
 And since the number one reason for having a CA in the root list is
 for Mozilla-software user security, how do you arrive at punish [...]
 millions of users?
 
 If all of Comodo's certs cease to be trusted, millions of web surfers will see
 errors on potentially thousands of sites.
 
 This leads me to believe that there are three possibilities:
 1) You have communication from Robin about the number of certificates
 that Comodo has issued that the rest of us are not privy to, OR
 2) You have some way of knowing what CAs are in use by the servers
 that users of the Mozilla applications use (which concept rather
 scares me, since it hasn't been disclosed as part of the software
 operations), OR
 
 The fact you think these are even reasonably conclusions tells me a lot about
 your reasoning skills.
 
 3) You're pulling numbers out of thin air.
 
 Indeed, I am, as an educated guess. Comodo is a root CA. You don't get root
 status by having a handful of customers. It's hard business to break into, and
 Comodo has been around a while. I find it hard to believe a company of their
 size and age has any fewer than ten thousand certs out there, and that's a
 lowball guess. There are many hundreds of millions of web users, and millions
 of websites. Do you really find it hard to believe at least 1% of those secure
 sites might be using a Comodo cert?
 

For my own installation of SeaMonkey, I disabled all Comodo roots as
soon as I understood the problem.  I disabled all UserTrust roots some
years ago, for reasons I don't remember.  I have yet to encounter a
problem with any Web site because of this.

The several financial institutions where I access accounts via the Web
-- the Web sites for which I'm most concerned -- all seem to use either
VeriSign or Equifax for their SSL site certificates.  My ISP's Web-mail
interface uses Equifax as does the domain registry where I maintain two
domains.  Amazon.com uses VeriSign.

I'm beginning to wonder what important Web sites do use Comodo.

-- 
David E. Ross
http://www.rossde.com/

Go to Mozdev at http://www.mozdev.org/ for quick access to
extensions for Firefox, Thunderbird, SeaMonkey, and other
Mozilla-related applications.  You can access Mozdev much
more quickly than you can Mozilla Add-Ons.
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Re: dropping the root is useless

2008-12-29 Thread Ben Bucksch

On 29.12.2008 07:59, Nelson B Bolyard wrote:

Perhaps the policy should even go so far, as Kai has suggested, as to
require that whatever entity performs the verification of subject
identity for the CA must be audited.
   


Yes. Not perhaps.
The verification is one of the two core operations of the CA (the other 
is to sign the certs and keep the key secure). The verifications are 
what the audit is all about. Of course the verifications, and whoever 
does that, have to be audited. That means watching the actual, real 
people, who do the verifications. That's what we need - we need 
*somebody* (preferably many, even) independent to verify that the CA 
actually does what it says it does, actually, in real world, everyday 
business.


A paper is useless, if nobody verifies that it's actually followed.

Everything else is just talk, hot air.
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Re: dropping the root is useless

2008-12-29 Thread Grey Hodge
On 12/29/2008 4:46 PM Eddy Nigg cranked up the brainbox and said:
 The amount of customers never was a known criteria of CAs business 
 practices ever.

I also don't know how many Credit cards Bank of America issues, but I can
guess with reasonable accuracy.

 Isn't the responsibility of a CA this size much greater and breach of 
 trust going to affect many? Is a breach of trust justified and 
 acceptable because of the size of a CA or shouldn't that CA provide 
 extra care?

Considering the KNOWN size of the breach, a maximum of 111 certs, less than
ten percent of which could not be verified in 2 days, only 2 of which were
confirmed to be fraudulent (both your attempts), I don't think this requires a
revocation. If we /can/ resolve this issue without revoking, why shouldn't we?

 (For your knowledge, Netcraft confirms

There's a reason netcraftconfirmsit is a tag on Slashdot, and it's not
because Netcraft is a bastion of statistical rigor.

My point still stands. Revoking Comodo certs would be a needlessly messy and
painful endeavour, and should be avoided if the situation can be resolved
elsewise. So far, I have no reason to believe Comodo can't tighten up their
practices without nuking millions of web surfers.

-- 
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 email [ grey @ burntelectrons.org ]
 web   [ http://burntelectrons.org ]
 tag   [ Don't touch that! You might mutate your fingers! ]
 motto [ Make everything as simple as possible, but no simpler. - Einstein ]
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Re: dropping the root is useless

2008-12-29 Thread Kyle Hamilton
I would LOVE for Comodo to clean up its practices.

Including decertifying the CA that does not adhere to financial
levels of control that is certified by a CA that does.

-Kyle H

On Mon, Dec 29, 2008 at 5:44 PM, Grey Hodge g...@burntelectrons.org wrote:
 On 12/29/2008 4:46 PM Eddy Nigg cranked up the brainbox and said:
 The amount of customers never was a known criteria of CAs business
 practices ever.

 I also don't know how many Credit cards Bank of America issues, but I can
 guess with reasonable accuracy.

 Isn't the responsibility of a CA this size much greater and breach of
 trust going to affect many? Is a breach of trust justified and
 acceptable because of the size of a CA or shouldn't that CA provide
 extra care?

 Considering the KNOWN size of the breach, a maximum of 111 certs, less than
 ten percent of which could not be verified in 2 days, only 2 of which were
 confirmed to be fraudulent (both your attempts), I don't think this requires a
 revocation. If we /can/ resolve this issue without revoking, why shouldn't we?

 (For your knowledge, Netcraft confirms

 There's a reason netcraftconfirmsit is a tag on Slashdot, and it's not
 because Netcraft is a bastion of statistical rigor.

 My point still stands. Revoking Comodo certs would be a needlessly messy and
 painful endeavour, and should be avoided if the situation can be resolved
 elsewise. So far, I have no reason to believe Comodo can't tighten up their
 practices without nuking millions of web surfers.

 --
 Grey Hodge
  email [ grey @ burntelectrons.org ]
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Re: dropping the root is useless

2008-12-29 Thread Eddy Nigg

On 12/30/2008 03:44 AM, Grey Hodge:


Considering the KNOWN size of the breach, a maximum of 111 certs, less than
ten percent of which could not be verified in 2 days, only 2 of which were
confirmed to be fraudulent (both your attempts), I don't think this requires a
revocation. If we /can/ resolve this issue without revoking, why shouldn't we?


Well Grey, this is only what we know for an almost certainty. There is a 
big question about what we don't know. There are contradicting practice 
statements and one of them suggests that there might be more 
(unvalidated certs), the other one suggest that validation isn't 
performed by Comodo, even if required as per their policy.



There's a reason netcraftconfirmsit is a tag on Slashdot, and it's not
because Netcraft is a bastion of statistical rigor.


Still, it gives a better indication.



So far, I have no reason to believe Comodo can't tighten up their
practices without nuking millions of web surfers.



That would be great, this is really, really what we want here. There is 
no fun in pulling a root, that's for emergencies. I'm certain, whatever 
Comodo is going to do in this respect will influence any decision taken 
at Mozilla. Hopefully Robin will tell us soon more...



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Re: dropping the root is useless

2008-12-28 Thread Eddy Nigg

On 12/28/2008 02:46 PM, Ian G:


1. Certs: All end-users who rely on these certs will lose. That probably
numbers in the millions. All subscribers will lose, probably in the
thousands. The CA will lose; potentially it will lose its revenue
stream, or have it sliced in half (say), which is what we would call in
business circles a plausible bankrupcy event.


Not relevant.


2. Mozo: Mozilla will lose because of all the undelivered security (all
those good certs and subscribers and end-users). It may be sued by the
CA and the CA's investors and/or the receiver/liquidator for a bad
decision.


I suggest to you refrain from now on to give legal advice on these 
matters, Mozilla has a legal department and lawyers for that. But if we 
are at it, Mozilla has no legal or any other requirement (as far as I 
know) to include or keep a root. The Mozilla CA Policy clearly reserves 
the right to remove any of the roots (including all of them) at any 
time. If this isn't the case we all should know about it. Additionally 
it's Mozilla which also has the right to sue the CA and not the other 
way around. Just for your knowledge, Microsoft and other vendors reserve 
the same right.



3. Industry: All other CAs will lose because they will now have to
include in their business plans the possibility of a root being dropped
by a bad decision.


Very good! Even though I'm not the proponent of the proposal to remove 
Comodo's root (instead work towards a real improvement, with the removal 
as a stick), this is exactly what possible removal should achieve. 
Refrain CAs from making bad decisions. More than that, some CAs are on 
disadvantage when competing with CAs which are willing to take high 
risks. This must be clearly recognized and I'm all in favor of having to 
compete on equal footing. This isn't the case today.




4. Security will go down, because less certs are delivered and in use.
(It's hard to calculate the secondary losses here, but not impossible.)


That's easy to revert, I'm certain there are a bunch of CAs ready to 
issue new certs to them.



1. Against that you can weigh the damages done so far and the harm to
protect against. We know it is down to 11 or so certs, all revoked.


That's absolutely not correct. Right now nobody knows - including Comodo 
- how many certs are really unvalidated because of the lack thereof. 
This is what I know at the moment and it would be good if Comodo could 
dispute that claim and advice differently or confirm it.



2. There is the possible benefit to the other CAs as a punishment tool,
in the case where the decision is good (see 3. above). There could be a
knock-on effect in convincing CAs to tighten their game.


Right! I'm all in favor of that, lets go for it!


However, this
needs to be balanced against other costs and loss of certs, and in
practice, the dominant factor is this: more certs is more security, less
certs is less security.


Less unvalidated certs is more security, not less. An unknown number of 
unvalidated certs is no security at all.



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Re: dropping the root is useless

2008-12-28 Thread Ian G
(following is just for the record so as to deal with the response.  No 
new info is in here for other readers.)




On 28/12/08 14:21, Eddy Nigg wrote:

On 12/28/2008 02:46 PM, Ian G:


1. Certs: All end-users who rely on these certs will lose. That probably
numbers in the millions. All subscribers will lose, probably in the
thousands. The CA will lose; potentially it will lose its revenue
stream, or have it sliced in half (say), which is what we would call in
business circles a plausible bankrupcy event.


Not relevant.



Well!  If they are not relevant, then perhaps we can turn SSL off, with 
no consequences?




I suggest to you refrain from now on to give legal advice on these
matters, Mozilla has a legal department and lawyers for that. But if we
are at it,



Let's deal with this self-contradictory statement.

To ignore the obvious legal ramifications (agreements in RPAs, 
disclaimers to end-users, potential lawsuits ...) would be negligence, IMHO.


We know the ramifications exist.  We know they may be serious.  We know 
that assertations of security are being made to end-users.  Hence to 
continue making these assertations, and not treat them seriously would 
be negligence.


I personally choose not to follow that path into negligence, and will 
continue to consider the legal ramifications, which leads to the 
question of how we consider them.


We could simply refer them to the legal department, as you suggest. 
Mozilla has a legal department, as you kindly point out, but they are 
silent.  They may have entirely good reasons for being silent, but that 
makes them more or less useless for the work of this forum.  So 
referring them to that legal department is not an option for now.


We could simply refer them to our own legal department.  But, we are all 
here as volunteers, and while some of the businesses may like to put 
their counsel at the service of this group, this won't work because of 
conflicts of interest.  This is therefore not an option.


Which leaves the final option:  we have to deal with it, ourselves, and 
we have to work with the known and understood caveats that none of us 
are lawyers.




Others may have other views, but I would suggest that in this forum, we 
have to consider the legal ramifications.




Mozilla has no legal or any other requirement (as far as I
know) to include or keep a root.



No, I'm afraid there is an agreement to list the root, under a policy. 
Once listed, Mozilla has to operate according to its side of the bargain.


This is a general consequence of business, there is nothing special 
about it.  Ask any experienced business person.




The Mozilla CA Policy clearly reserves
the right to remove any of the roots (including all of them) at any
time. If this isn't the case we all should know about it.



The problem being, that even if it reserves the right to make a choice 
for any reason, this does not give Mozilla carte blanche.  If it makes a 
bad choice, a judge can imply a reasonableness test.


This is one of those areas where we really do need lawyers in the 
conversation, but I will short circuit that with a prediction of mine, only:


the lawyers will likely say, we will find out in court.

Great answer, huh?  It sure keeps the lawyers in work, and it provides 
little help for us.  See earlier analysis.




Additionally
it's Mozilla which also has the right to sue the CA and not the other
way around. Just for your knowledge, Microsoft and other vendors reserve
the same right.



Everyone has the right to walk into court.  That point is empty of 
practical value.




3. Industry: All other CAs will lose because they will now have to
include in their business plans the possibility of a root being dropped
by a bad decision.


Very good! Even though I'm not the proponent of the proposal to remove
Comodo's root (instead work towards a real improvement, with the removal
as a stick), this is exactly what possible removal should achieve.



Please read it carefully.  a root being dropped by a BAD decision.



Refrain CAs from making bad decisions.



Oh, ok.  No, I meant MOZILLA making a bad decision.  E.g., a mistake.



More than that, some CAs are on
disadvantage when competing with CAs which are willing to take high
risks. This must be clearly recognized and I'm all in favor of having to
compete on equal footing. This isn't the case today.



Indeed.  You won't achieve it by dropping a root, and you won't achieve 
it by _threatening_ to drop a root.


I suggest you will achieve precisely the reverse, because some CAs will 
have an advantage in that negotiation, and they will overcome any 
positive benefit in a way that has little bearing on security for the users.


Standard business stuff, really.



4. Security will go down, because less certs are delivered and in use.
(It's hard to calculate the secondary losses here, but not impossible.)


That's easy to revert, I'm certain there are a bunch of CAs ready to
issue new certs to them.




Re: dropping the root is useless

2008-12-28 Thread Eddy Nigg

On 12/28/2008 04:24 PM, Ian G:

1. Certs: All end-users who rely on these certs will lose. That probably
numbers in the millions. All subscribers will lose, probably in the
thousands. The CA will lose; potentially it will lose its revenue
stream, or have it sliced in half (say), which is what we would call in
business circles a plausible bankrupcy event.


Not relevant.



Well! If they are not relevant, then perhaps we can turn SSL off, with
no consequences?



I was clearly replying to the later part:

The CA will lose; potentially it will lose its revenue stream, or have 
it sliced in half (say), which is what we would call in business circles 
a plausible bankrupcy event.


It's not relevant.



No, I'm afraid there is an agreement to list the root, under a policy.
Once listed, Mozilla has to operate according to its side of the bargain.



Apparently you are reading something I haven't.


The problem being, that even if it reserves the right to make a choice
for any reason, this does not give Mozilla carte blanche.


Mozilla can make a bad decision, no doubt. This case is most likely not 
one of those you are referring to.




Please read it carefully. a root being dropped by a BAD decision.


A root isn't removed before careful considerations. A bad decision 
doesn't warrant not to remove any roots at all if necessary. Mozilla can 
also reinstate a root.




They stated how many, IIRC. I recall it was something like 111 certs
issued and 11 outstanding that had not been re-verified within around 48
hours (these numbers are not accurate, but indicative) and were
therefore revoked.


That's for the specific certstar case. Domain validation isn't performed 
by Comodo on a wide scale apparently and perhaps no validation is 
performed at all.



--
Regards

Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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Re: dropping the root is useless

2008-12-28 Thread Ian G

On 28/12/08 15:42, Eddy Nigg wrote:

On 12/28/2008 04:24 PM, Ian G:
I was clearly replying to the later part:

The CA will lose; potentially it will lose its revenue stream, or have
it sliced in half (say), which is what we would call in business circles
a plausible bankrupcy event.

It's not relevant.



Well, that part may not be a loss that effects a security discussion. 
But I've made the point before that economic interests are much more 
important and may be dominant.  See below the discussion of lawyers.


So perhaps you won't mind if I keep bringing them up.  We might simply 
disagree as to their practical relevance to the real world discussion.




No, I'm afraid there is an agreement to list the root, under a policy.
Once listed, Mozilla has to operate according to its side of the bargain.



Apparently you are reading something I haven't.



Statements (policy, etc) plus actions gives rise to an agreement.  The 
agreement doesn't have to be written in one document to exist, it can 
exist without anything to read, or with many things to read.




The problem being, that even if it reserves the right to make a choice
for any reason, this does not give Mozilla carte blanche.


Mozilla can make a bad decision, no doubt. This case is most likely not
one of those you are referring to.



Well, who is going to warrant that for Mozilla?



Please read it carefully. a root being dropped by a BAD decision.


A root isn't removed before careful considerations. A bad decision
doesn't warrant not to remove any roots at all if necessary. Mozilla can
also reinstate a root.



If in court, we can be sure that the CA will argue that the decision is 
bad.  The judge will bend over backwards to let the CA make that case; 
that's what the court is there for.


(This then turns on who has the burden, and what question has to be 
answered.  Er, now we need the lawyers.)




What I'm about here is that:  in any wider business analysis, the answer 
is that, short of total collapse, do not remove the root.  And if there 
is total collapse, you will be wrong regardless, so it doesn't really 
matter what you do.


I am not saying I *like* it.  In fact, I don't like it.

I'm saying the tool is bankrupt.  Think of other tools, this one will 
not work for you.




Let me put it another way:  one phone call from the CA's lawyer to 
Mozo's lawyer is probably sufficient to solve this problem *for the CA*.


Ask yourself whether you have a lawyer.  Ask your lawyer whether he can 
make the phone call.  Ask your lawyer how the phone call will go (he 
doesn't need to make it).


Let us know what he says, for the education of us all.



They stated how many, IIRC. I recall it was something like 111 certs
issued and 11 outstanding that had not been re-verified within around 48
hours (these numbers are not accurate, but indicative) and were
therefore revoked.


That's for the specific certstar case. Domain validation isn't performed
by Comodo on a wide scale apparently and perhaps no validation is
performed at all.



Oh, that's a new claim, beyond this reseller.

Is there any evidence?  If so, then maybe there should likely be a new 
investigation, and widespread revocations by the CA of the non-verified 
certs.  OK, as discussed earlier, actual investigations are outside 
scope of here (which begs the important question of where it is in scope 
of!) so let's not speculate further on Comodo's exact position.


Back to the damages estimate:  we still need to form an estimate of how 
many certificates were issued to people of malintent.


Without that, we are still left with a damages estimate of zero, albeit 
one multiplied by a much larger number of users, with a much greater 
range of possible error.


iang
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Re: dropping the root is useless

2008-12-28 Thread David E. Ross
On 12/28/2008 4:46 AM, Ian G wrote [in part]:
 On 28/12/08 12:13, Kai Engert wrote:
 
 If we'd like to be strict, we could remove CAs from our approved list if
 they have shown to be non-conforming in the above way.
 
 
 Yes, we could!  But this is what we call a blunt weapon.  It is also a 
 dangerous weapon.  Consider (all) the consequences in the current case.
 
 First, losses we will incur, regardless:
 
1.  Certs:  All end-users who rely on these certs will lose.  That 
 probably numbers in the millions.  All subscribers will lose, probably 
 in the thousands.  The CA will lose;  potentially it will lose its 
 revenue stream, or have it sliced in half (say), which is what we would 
 call in business circles a plausible bankrupcy event.
 

So when a CA behaves badly, we should still be concerned that the CA
might lose money?  Because a CA might go bankrupt, we should do nothing?

How about the users of Mozilla products who might lose money or even go
bankrupt because they trusted a root certificate from such a CA?  No,
such losses are not known (yet).  What did happen, however, indicates
that such losses are indeed possible and not only through Certstar.

-- 
David E. Ross
http://www.rossde.com/

Go to Mozdev at http://www.mozdev.org/ for quick access to
extensions for Firefox, Thunderbird, SeaMonkey, and other
Mozilla-related applications.  You can access Mozdev much
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Re: dropping the root is useless

2008-12-28 Thread Kyle Hamilton
On Sun, Dec 28, 2008 at 6:24 AM, Ian G i...@iang.org wrote:
 (following is just for the record so as to deal with the response.  No new
 info is in here for other readers.)

I would very much appreciate it if you would stop using fear,
uncertainty, and doubt to manipulate the audience into believing your
and only your viewpoint.

Unlike you, Eddy actually runs a certifying authority.  This means
that he has operational experience with not only the technical sides
of things, but also the legal sides of things.

Just because you also happen to be an advocate for CAcert (and --
unlike Eddy -- feel the urge to hide that affiliation) does not mean
that you actually run it, or have the depth or breadth of knowledge
necessary to do so.  This message shows me that you honestly don't
care about what security actually is, you just care about the
end-user experience.  This is NOT the same thing.  As such, my
opinion of your authority on the subject matter has diminished
severely.

True security involves knowing what the risks are.  Mozilla's policy
for root inclusion tries to reduce the uncertainty for end-users;
unfortunately, as has been pointed out repeatedly, there is still far
too much uncertainty for end-users in Comodo's operations.  They have
lost my trust, the same way that you have.

 On 28/12/08 14:21, Eddy Nigg wrote:

 On 12/28/2008 02:46 PM, Ian G:

 1. Certs: All end-users who rely on these certs will lose. That probably
 numbers in the millions. All subscribers will lose, probably in the
 thousands. The CA will lose; potentially it will lose its revenue
 stream, or have it sliced in half (say), which is what we would call in
 business circles a plausible bankrupcy event.

 Not relevant.


 Well!  If they are not relevant, then perhaps we can turn SSL off, with no
 consequences?

If Nelson can upbraid me for ad hominem attacks, I'm going to upbraid
you for ad absurdem arguments.

TLS (can we PLEASE stop using SSL, since the last version of SSL
that got ratified by any standards organization was SSLv2, and SSLv3
is a hack that reached internet-draft phase but was never formally
recognized?) has the option of negotiating a secure connection without
the use of any certificates at all.  (Further, SSLv3 also had the same
mechanism.)

There's still the endpoint confidentiality concept -- nobody between
the client and the server that the client is talking to can hear
what's being said between them.  The problem that certificates (or key
continuity management) is designed to solve is the problem where the
client thinks it's talking to one server, when it's really talking to
another (the fraudulent endpoint attack in the case where the
server-endpoint doesn't pass any data to the real server, and the man
in the middle attack in the case it does).

 To ignore the obvious legal ramifications (agreements in RPAs, disclaimers
 to end-users, potential lawsuits ...) would be negligence, IMHO.

 We know the ramifications exist.  We know they may be serious.  We know that
 assertations of security are being made to end-users.  Hence to continue
 making these assertations, and not treat them seriously would be negligence.

 I personally choose not to follow that path into negligence, and will
 continue to consider the legal ramifications, which leads to the question of
 how we consider them.

In my mind (and this is not legal advice, merely a statement of
thought presented for the purposes of argument), Mozilla has a duty to
me as an end-user to uphold the letter and spirit of its CA
Certificate Policy.  I've already presented my thought on how a full
tort could be brought against Mozilla by the operator of any CA
already in the trust list.  If a Comodo-issued certificate causes any
user damage after the initial disclosure on the list, a tort could be
brought against Mozilla by that end-user.

 Mozilla has no legal or any other requirement (as far as I
 know) to include or keep a root.

 No, I'm afraid there is an agreement to list the root, under a policy. Once
 listed, Mozilla has to operate according to its side of the bargain.

The policy explicitly provides for Mozilla removing a root, at its
option.  Section 4 of the CA Certificate Policy: We reserve the right
to not include a particular CA certificate in our software products,
to discontinue including a particular CA certificate in our products,
or to modify the trust bits for a particular CA certificate included
in our products, at any time and for any reason.

It gives examples of the situations that it could do so in, but it
also explicitly states that its appropriate reasons for doing so ARE
NOT LIMITED TO those examples.

Please also recognize that the right and protection of the many tends,
at least in the US court system that Mozilla and Comodo are subject
to, outweighs the right and protection of the few or one (the company
which operates the CA).

 This is a general consequence of business, there is nothing special about
 it.  Ask any experienced 

Re: dropping the root is useless

2008-12-28 Thread Kyle Hamilton
On Sun, Dec 28, 2008 at 9:28 AM, Ian G i...@iang.org wrote:
 On 28/12/08 17:06, David E. Ross wrote:
 How about the users of Mozilla products who might lose money or even go
 bankrupt because they trusted a root certificate from such a CA?  No,
 such losses are not known (yet).  What did happen, however, indicates
 that such losses are indeed possible and not only through Certstar.

 Yes, indeed.  That's a big question.

 What I am suggesting is that dropping the root will not address that
 question.  It is too blunt a weapon to be used reliably.

Considering that trustability is viewed as a binary state, it's the
only weapon that Mozilla has.

-Kyle H
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Re: dropping the root is useless

2008-12-28 Thread Ian G

On 29/12/08 00:37, Kyle Hamilton wrote:

On Sun, Dec 28, 2008 at 9:28 AM, Ian Gi...@iang.org  wrote:

On 28/12/08 17:06, David E. Ross wrote:

How about the users of Mozilla products who might lose money or even go
bankrupt because they trusted a root certificate from such a CA?  No,
such losses are not known (yet).  What did happen, however, indicates
that such losses are indeed possible and not only through Certstar.

Yes, indeed.  That's a big question.

What I am suggesting is that dropping the root will not address that
question.  It is too blunt a weapon to be used reliably.


Considering that trustability is viewed as a binary state, it's the
only weapon that Mozilla has.



Yes.  This is reason for concern.

iang
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Re: dropping the root is useless

2008-12-28 Thread Kyle Hamilton
On Sun, Dec 28, 2008 at 3:42 PM, Ian G i...@iang.org wrote:
 On 29/12/08 00:37, Kyle Hamilton wrote:
 Considering that trustability is viewed as a binary state, it's the
 only weapon that Mozilla has.


 Yes.  This is reason for concern.

FWIW, I agree.

Alright, I propose that, in a new thread, we open the table for
discussion of the problems inherent in the binary-state model, and
ways to mitigate these problems?

-Kyle H
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Re: dropping the root is useless

2008-12-28 Thread Ian G

On 29/12/08 00:36, Kyle Hamilton wrote:

On Sun, Dec 28, 2008 at 6:24 AM, Ian Gi...@iang.org  wrote:




Unlike you, Eddy actually runs a certifying authority.  This means
that he has operational experience with not only the technical sides
of things, but also the legal sides of things.



I support your right to an opinion, but can you please ground your 
criticisms in facts of relevance, rather than ad hominims.




Just because you also happen to be an advocate for CAcert


Strawman.  An Auditor is perhaps an advocate in the sense that he writes 
an opinion.  I have not done that, and won't for another 6 months at 
current progress.  Here's *just* the local dirt:


https://bugzilla.mozilla.org/show_bug.cgi?id=215243#c158

I think the advocacy claim looks a little silly, no?  Absurd, even.



(and --
unlike Eddy -- feel the urge to hide that affiliation)  does not mean
that you actually run it, or have the depth or breadth of knowledge
necessary to do so.  This message shows me that you honestly don't
care about what security actually is, you just care about the
end-user experience.  This is NOT the same thing.  As such, my
opinion of your authority on the subject matter has diminished
severely.



You are entitled to your opinion, but I would ask you to consider that 
this is a policy forum, not an ad hominem shooting match.




True security involves knowing what the risks are.  Mozilla's policy
for root inclusion tries to reduce the uncertainty for end-users;
unfortunately, as has been pointed out repeatedly, there is still far
too much uncertainty for end-users in Comodo's operations.



The point I have made is that the discussion of Comodo's operations is 
outside scope of this forum.  You may feel that you have an opinion, and 
you have a right to it.  However, this forum is not for the 
investigation of breaches or failures to comply with policies.


If you dislike that, don't start a war against me.  Suggest a policy 
change to Mozilla.  If you want wordings, try this:


   x.  Any breaches of security or failures to comply will be
   discussed in the policy forum of Mozilla, a ruling by consensus
   delivered, and will be binding on the CA.

Don't disagree with me in a post, do something.  Write the proposal, 
change the policy.  Words are less important than acts.




They have
lost my trust, the same way that you have.



Now over to you.  Act, not talk.  Make a dispute resolution forum happen.



On 28/12/08 14:21, Eddy Nigg wrote:

On 12/28/2008 02:46 PM, Ian G:

1. Certs: All end-users who rely on these certs will lose. That probably
numbers in the millions. All subscribers will lose, probably in the
thousands. The CA will lose; potentially it will lose its revenue
stream, or have it sliced in half (say), which is what we would call in
business circles a plausible bankrupcy event.

Not relevant.


Well!  If they are not relevant, then perhaps we can turn SSL off, with no
consequences?


If Nelson can upbraid me for ad hominem attacks, I'm going to upbraid
you for ad absurdem arguments.

TLS (can we PLEASE stop using SSL, since the last version of SSL
that got ratified by any standards organization was SSLv2, and SSLv3
is a hack that reached internet-draft phase but was never formally
recognized?) has the option of negotiating a secure connection without
the use of any certificates at all.  (Further, SSLv3 also had the same
mechanism.)

There's still the endpoint confidentiality concept -- nobody between
the client and the server that the client is talking to can hear
what's being said between them.  The problem that certificates (or key
continuity management) is designed to solve is the problem where the
client thinks it's talking to one server, when it's really talking to
another (the fraudulent endpoint attack in the case where the
server-endpoint doesn't pass any data to the real server, and the man
in the middle attack in the case it does).



Er, Kyle, you are off on a tangent here.  My point with Eddy was fully 
addressed by him pointing out that he was only dealing with the last 
sentance, I thought he was referring to the earlier sentances.  A 
reasonable clarification.




To ignore the obvious legal ramifications (agreements in RPAs, disclaimers
to end-users, potential lawsuits ...) would be negligence, IMHO.

We know the ramifications exist.  We know they may be serious.  We know that
assertations of security are being made to end-users.  Hence to continue
making these assertations, and not treat them seriously would be negligence.

I personally choose not to follow that path into negligence, and will
continue to consider the legal ramifications, which leads to the question of
how we consider them.


In my mind (and this is not legal advice, merely a statement of
thought presented for the purposes of argument), Mozilla has a duty to
me as an end-user to uphold the letter and spirit of its CA
Certificate Policy.  I've already presented my thought on how a full
tort could be 

Re: dropping the root is useless

2008-12-28 Thread Eddy Nigg

On 12/29/2008 03:09 AM, Ian G:


The point I have made is that the discussion of Comodo's operations is
outside scope of this forum. You may feel that you have an opinion, and
you have a right to it. However, this forum is not for the investigation
of breaches or failures to comply with policies.

If you dislike that, don't start a war against me. Suggest a policy
change to Mozilla. If you want wordings, try this:

x. Any breaches of security or failures to comply will be
discussed in the policy forum of Mozilla, a ruling by consensus
delivered, and will be binding on the CA.



I don't think you are entirely correct, Ian. The community has its say, 
is free to discuss, suggest, propose, vent its anger and more. The 
ultimate decision lies with Frank and Mozilla's management, however 
discussions, suggestions, opinions, proposals are an important part of 
shaping those decisions I think. I'm saying this from experience as many 
times the mentioned above influenced decisions and/or resulted directly 
in actions. I think this is what makes Mozilla incredible unique.


Not every objection, suggestion or proposal results in a standing 
ovation obviously, but overall I'm quite pleased. And it's a two way 
street many times, as members of Mozilla and the community made 
suggestions or voiced their opinion, which directly lead to changes at 
the company *I* run. Sometimes this happened in the public forums, 
sometimes in private. The decisions are taken obviously elsewhere, 
however this forum directly influenced some them.


In that respect I disagree that this forum isn't the right place to 
discuss, disclose, propose, exchange thoughts and even investigate. I 
wouldn't know a better place. And in the same time, I'd disagree that 
the community should make the ultimate decision, the responsibility is 
clearly with the Mozilla Foundation (?) and must be decided there.



--
Regards

Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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Re: dropping the root is useless

2008-12-28 Thread David E. Ross
On 12/28/2008 3:45 PM, Kyle Hamilton wrote [in part]:
 CertStar was found out, only due to the diligence of someone on this
 list.  How many other RAs haven't been found out yet?  We can't know,
 because Comodo won't say.  This affects the confidence I have in their
 system (i.e., it removes ALL confidence that Mozilla extended on my
 behalf).

Actually, Eddy discovered the problem only through the fortuitous
receipt of spam from CertStar.  If he had not received the spam -- even
if others had received it -- it is possible the problem would never have
been discovered.  This is why the discovery is so frightening.

Now that it is known that a subordinate reseller operating under one CA
issued certificates without authenticating the identity of the
subscribers, we know that the theoretical concern expressed (before all
this) about resellers is no longer theoretical.  NOW is the time to
require that all CAs supervise the operations of their RAs and
resellers.  This must be done in a way that independent audits of the
CAs examine the implementation of such supervision, which can be
accomplished by requiring (at least with respect to the Mozilla
database) that CPs explicitly address how that supervision is performed.

Either a CA's CP must explicitly state that there are NO external RAs or
resellers, or else the CP must describe how external subordinates are
monitored.  Without this, a CA's request to have its root certificate
included in the Mozilla database should be denied.  Since an audit will
generally report on the implementation of such a policy but not
necessarily on the policy's adequacy, the internal and public reviews of
CA requests must examine the adequacy of the CA's policy for monitoring
external subordinates.

-- 
David E. Ross
http://www.rossde.com/

Go to Mozdev at http://www.mozdev.org/ for quick access to
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Re: dropping the root is useless

2008-12-28 Thread Nelson B Bolyard
David E. Ross wrote, On 2008-12-28 21:40 PST:

 Now that it is known that a subordinate reseller operating under one CA 
 issued certificates without authenticating the identity of the 
 subscribers, we know that the theoretical concern expressed (before all 
 this) about resellers is no longer theoretical.  NOW is the time to 
 require that all CAs supervise the operations of their RAs and resellers.
 This must be done in a way that independent audits of the CAs examine the
 implementation of such supervision, which can be accomplished by
 requiring (at least with respect to the Mozilla database) that CPs
 explicitly address how that supervision is performed.
 
 Either a CA's CP must explicitly state that there are NO external RAs or 
 resellers, or else the CP must describe how external subordinates are 
 monitored.  Without this, a CA's request to have its root certificate 
 included in the Mozilla database should be denied.

+1

Perhaps the policy should even go so far, as Kai has suggested, as to
require that whatever entity performs the verification of subject
identity for the CA must be audited.

Section 6 of the policy requires that all CAs whose certificates are
distributed with our software products must prior to issuing certificates,
verify certificate signing requests in a manner that we deem acceptable,
and provide attestation of their conformance to the stated verification
requirements and other operational criteria by a competent independent party
or parties with access to details of the CA's internal operations.

I think that last part clearly assumed that the verification requirements
were part of the CA's internal operations, an assumption that we now know
is untrue.  So, I would suggest changing it from access to details of the
CA's internal operations to access to the details of the operations that
verify the certificate signing requests, whether internal or external

 Since an audit will generally report on the implementation of such a
 policy but not necessarily on the policy's adequacy, the internal and
 public reviews of CA requests must examine the adequacy of the CA's
 policy for monitoring external subordinates.

Yes.  Agreed.  I think the policy should define some parameters (bounds)
for determining the adequacy of CSR verification.  It is acceptable to
have hundreds of parties each responsible for verifying CSRs for a
single CA (single issuer)?  If not, what limit should apply?

I'd like to see any statements made by Mozilla at the beginning of the
week of public review to explicitly speak to the CSR verification process,
and whether it is internal or external, and how many RAs (or parties
entrusted with verifying CSRs) exist for the particular CA (organization),
and the number of CSR verification parties per subordinate CA.
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Re: dropping the root is useless

2008-12-28 Thread Grey Hodge
On 12/28/2008 9:42 AM Eddy Nigg cranked up the brainbox and said:
 On 12/28/2008 04:24 PM, Ian G:
 No, I'm afraid there is an agreement to list the root, under a policy.
 Once listed, Mozilla has to operate according to its side of the bargain.
 Apparently you are reading something I haven't.

Apparently, but that doesn't mean it's invalid. Mozilla can't act arbitrarily
and without cause and expect to retain any shred of respect or
trustworthiness. A policy not adhered to is worthless.

 That's for the specific certstar case. Domain validation isn't performed 
 by Comodo on a wide scale apparently and perhaps no validation is 
 performed at all.

Yes, perhaps, and perhaps they send out certs to anyone who asks nicely, but
we have little evidence to support these suppositions.

Rather than having a kneejerk reaction of removing Comodo from the root list,
why don't we examine the situation. This reseller was not acting according to
proper procedure. Comodo immediately revoked their reseller status, and
reviewed their certs. Further, they've said they're reviewing their policies
to ensure this doesn't happen again. Given their candor and quick response,
what more do you require that you feel you're not getting that justified
removing them as a root CA?

I really think you're going overboard. Form what I see, I'm not alone in that
assessment. You did a good job in bringing this to light. Having the issues
you uncovered addressed and fixed should be sufficient. Why do we need to take
punitive action that will do nothing but punish tens of thousands of other
Comodo customers and millions of users?

-- 
Grey Hodge
 email [ grey @ burntelectrons.org ]
 web   [ http://burntelectrons.org ]
 tag   [ Don't touch that! You might mutate your fingers! ]
 motto [ Make everything as simple as possible, but no simpler. - Einstein ]
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