I checked with Max Pala, and he confirmed that the OpenCA software
(an open source CA package) is also capable of generating a Subject
or Issuer name that is just a single set consisting of a common name
attribute and the serial number attribute.
with this info I think we are safe to proceed to mandate this name
format. I agree with Russ' observation that this is not a common
format and that it might confuse a user viewing it. However, since
these names are not intended to be human meaningful, and will not be
popping in in a browser or an S/MIME message, I don't think this is a
serious concern.
Steve
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