Hi Deb,
On 7/10/26 12:25, Deb Cooley wrote:
I will only respond to two points (divided):
1. My warning to the list: Indeed, if a 'new participant' violates
any of the stated policies, they will receive a private warning
before any further action.
Thanks for clarifying. I think such warnings can have a chilling effect.
Ken's email suggests that this was not merely hypothetical. It landed
differently from the regular mailing list conduct reminder text.
2a. Recusal: The topic of the working group last call is about a
draft, not about NSA, I perceive no reason to recuse.
Correct me if I am mistaken, but I recall that your IETF biography says
you spent a major part of your career at NSA namely IAD/CSD. I imagine
that it is frustrating to hear so much about NSA from people who know
comparatively little about NSA. It may also feel personal and unfair.
EKR's point about not making this personal is important, and I want to
be careful about that.
The issue is not personal. The issue is trust in a standards process.
RFC 7258 is relevant to this draft and to the working group. The entire
RFC is worth reading, but this is the most compact part:
To summarise: current capabilities permit some actors to monitor
content and metadata across the Internet at a scale never before
seen. This pervasive monitoring is an attack on Internet privacy.
The IETF will strive to produce specifications that mitigate
pervasive monitoring attacks.
That concern is not speculative, and it is not a conspiracy theory. The
NYT-published SIGINT Enabling budget exhibit says the project "actively
engages the US and foreign IT industries" to influence commercial
products and make them exploitable while their security appears intact
to users and other adversaries [3]. The same reporting and source
documents describe inserting vulnerabilities into commercial encryption
systems and influencing commercial public-key standards and
specifications [3][4][5].
DER SPIEGEL separately reported that documents seen by SPIEGEL showed
NSA agents traveling to IETF meetings "to gather information but
presumably also to influence the discussions there" [6]. For
transparency: I am one of the authors of the cited DER SPIEGEL
reporting. I am citing it here because the underlying documents and
reporting are directly relevant to the trust and standards-influence
issue under discussion. These are documented facts, and NSA justified
its activities as legal when we asked for comment.
The BULLRUN/TLS documents are not just general history about anti-crypto
work. The documents we published directly discuss TLS, SSL, IPsec, and
related operational decryption work. One SSL/TLS document uses the
phrases "Literally millions of sessions per day" and "need both sides of
conversation" in the context of SSL/TLS traffic analysis and attack
workflows for producing decryptions [10]. Another specifically names
GCHQ work on "TLS trends" in the BULLRUN context [11]. These were TLS
1.2-and-earlier era documents; the point here is not that TLS 1.3
existed then, but that TLS has long been a high-value target for
large-scale cryptographic exploitation. This draft is about a TLS
specification that will be targeted when deployed on the Internet by the
same machinery, often improved.
SPIEGEL also reported on Tailored Access Operations (TAO) operational
work exploiting weaknesses in the IT industry, including attacks against
network operators, endpoints, and infrastructure [7]. The larger public
record shows a sustained effort to defeat, weaken, influence, or route
around deployed cryptography, including TLS/SSL, VPN/IPsec, standards,
and commercial products [3][4][5][6][7][8][9][10][11].
This is why the topic of any TLS draft intended to secure Internet
traffic from large-scale third-party adversaries is, unfortunately, more
than merely adjacent to documented NSA activities. That does not mean
every former NSA employee is acting improperly.
It does mean that precision about roles, obligations, and limits
matters. Thus the question is not only whether you personally perceive a
conflict. It is also whether you can accept that others may reasonably
perceive one, given the history around Dual_EC_DRBG, NIST/NSA
cryptographic standards work, and documented NSA efforts to influence
commercial cryptographic standards. This is also why NSA involvement in
IETF leadership roles can be controversial. The BULLRUN program's
standards-influence work was not usually so overt.
I will also point out that I am retired from the US Federal
Government, and I have no obligations to them, just like any other
person changing companies wouldn't retain responsibilities of their
previous company.
One clarification, please: do you mean that you have no current
employment obligations to NSA?
For just one example: one hopes that you are able to read every single
one of my citations such as [8], [9], [10], and [11] without reporting
requirements or concerns. It is hard to reach a common understanding if
we are not all able to read the same documents.
I ask because former clearance holders generally retain continuing
nondisclosure obligations regarding classified information after
retirement. SF 312 says its obligations apply "at all times thereafter"
unless released in writing by an authorized U.S. Government
representative, and the ODNI SF 312 FAQ says a prior NDA remains "in
full force and effect for the lifetime of the individual" [1][2].
The distinction matters here because this discussion is happening
against a real trust deficit: NIST/NSA history around Dual_EC_DRBG,
public records about NSA participation in standards work, and documented
NSA efforts to influence commercial cryptographic standards [3][4][5][6].
Naturally, having a _current_ clearance would be a completely different
issue. The more that can be stated, the more these concerns can be
addressed and handled appropriately.
I am not asking you to disclose anything classified. I am asking whether
"no obligations" means only "no current employment duties," while
ordinary continuing secrecy obligations still apply.
Congratulations on your retirement, and thank you for your service.
Kind regards,
Jacob
[0] https://datatracker.ietf.org/doc/html/rfc7258
[1] https://www.gsa.gov/system/files/2024-06/SF312-23.pdf
[2] https://www.dni.gov/files/NCSC/documents/Regulations/
SF312_Frequently_Asked_Questions_Pamphlet_May_2022_Digital_Signature_Update.pdf
[3] http://www.nytimes.com/interactive/2013/09/05/us/documents-reveal-
nsa-campaign-against-encryption.html?_r=0
[4] http://www.propublica.org/article/the-nsas-secret-campaign-to-crack-
undermine-internet-encryption
[5] http://www.theguardian.com/world/2013/sep/05/nsa-gchq-encryption-
codes-security
[6] https://www.spiegel.de/international/germany/inside-the-nsa-s-war-
on-internet-security-a-1010361.html
[7] https://www.spiegel.de/international/world/the-nsa-uses-powerful-
toolbox-in-effort-to-spy-on-global-networks-a-940969.html
[8] https://cdn.prod.www.spiegel.de/
media/45b5a458-0001-0014-0000-000000035509/media-35509.pdf
[9] https://cdn.prod.www.spiegel.de/
media/25722dbd-0001-0014-0000-000000035510/media-35510.pdf
[10] https://cdn.prod.www.spiegel.de/
media/52751d2b-0001-0014-0000-000000035511/media-35511.pdf
[11] https://cdn.prod.www.spiegel.de/media/
cb7c4c91-0001-0014-0000-000000035512/media-35512.pdf
2b.The RFC 9151 was published in 2022, but in fact was completed
much earlier (it had to wait for DTLS 1.3 to be published). I'm not
sure what your point is here, but the RFC is a profile of (D)TLS 1.2
and 1.3 for a specific community.
2c. On the subject of general recusal for all things crypt: See:
https://mailarchive.ietf.org/arch/msg/
ssh/7KRZCX_bvZWUOG50HqDg_KVT77c/
If you want a feature request (attach an archive link to an email),
I suggest you contact the tools team (https://www.ietf.org/about/
groups/tools/ ).
Deb Cooley Sec AD
On Thu, Jul 9, 2026 at 10:48 PM Ken Kubota <[email protected]>
wrote:
In this message, I am responding collectively to the following
emails: - William Layton (NSA) - Deb Cooley (Sec AD)
Due to the high volume of traffic from this mailing list, I will
create a new email address. I would like to mention this in
advance to avoid any misunderstandings, as the new email address
will be registered before the current one is removed.
William Layton (NSA):
On Tue, 07 July 2026 [1]:
The two independent layers is all about implementation, not
cryptography. If you look at the more detailed solutions that
implement two layers you'll see separate boxes with firewalls,
intrusion detection, etc. placed between them. That concept is
orthogonal to a discussion of multiple algorithms.
My question was:
Why the apparent change of position?
In this PDF document, the NSA consistently requires the exact
opposite: a hybrid approach (two tunnels/layers).
1. The concept of a (parallel) hybrid approach is to safeguard
against failure of a single component. Whether the hybrid approach
is applied across implementation boundaries or across
cryptographic algorithms is irrelevant to the nature of the hybrid
approach. In this case, it safeguards against any (future)
compromise of ML-KEM (or weaknesses associated with it) by also
using ECC. Therefore, the distinction between implementation and
cryptography is irrelevant in this context.
2. Post-quantum algorithms are immature. RFC 9958 (Post-Quantum
Cryptography for Engineers) [2] from June 2026: "the post-quantum
algorithms face uncertainty about the underlying mathematics,
compliance issues, unknown vulnerabilities, and hardware and
software implementations that have not had sufficient maturing
time to rule out traditional cryptanalytic attacks and
implementation bugs." ECC was far better understood and studied at
the time it was standardized. I myself found it surprising how
quickly the NIST PQC standardization process took place. The
subsequent cryptanalytic breaks of several algorithms, including a
finalist, are therefore less surprising.
3. SIKE, a NIST finalist, was shown to be breakable in 2022, only
four years ago. Under these circumstances, cutting away the second
safety belt introduces unnecessary risk.
4. Moreover, contrary to the explicit recommendation of one of the
authors of ML-KEM/Kyber (Peter Schwabe), the hash was removed even
though it would help protect against attacks such as the NSA's
Dual_EC_DRBG backdoor, which NIST was ultimately forced to remove:
"Should those RNGs include the hash? Yes, of course. [...] Of
course, as you stated in a another message, the RNG output may
leak through all kind of other sources, but the hash in Kyber's
Ecnaps is a cheap "defense-in-depth" mechanism to ensure that we
don't add another source of leakage." [3] As the Kyber author
mentions correctly, adding the hash is inexpensive, and removing
it without a compelling justification raises legitimate concerns.
Given that the NSA's contribution was never disclosed ("The FOIA
results show that what NIST publicly labeled as the "Post Quantum
Cryptography Team, National Institute of Standards and Technology
(NIST), [email protected]" actually had more NSA members than NIST
members." [4]), these circumstances warrant careful scrutiny.
5. Anything other than using a hybrid approach here is difficult
to justify from a cryptographic perspective. This is especially
true given the risks outlined above. For these reasons, the hybrid
approach is explicitly recommended in RFC 9958 (Post- Quantum
Cryptography for Engineers) Section 15.4. [5]: "Hybrid key
exchange is recommended to enhance security against the HNDL
attack. Additionally, hybrid signatures provide for time to react
in the case of the announcement of a devastating attack against
any one algorithm, while not fully abandoning traditional
cryptosystems."
6. Virtually everyone else has also chosen a hybrid approach. Not
only did OpenSSH adopt a hybrid approach by default in 2022 ("use
the hybrid Streamlined NTRU Prime + x25519 key exchange method by
default (" [email protected]")" [6]), but it also
adopted another hybrid scheme only a few days ago ("OpenSSH 10.4
was released on 2026-07-06. [...] add experimental support for a
composite post-quantum signature scheme that combines ML-DSA 44
and Ed25519" [7]). Germany's NIST counterpart, the BSI, reaches
the same conclusion. Technical Guideline TR-02102-2 (version
2026-01): "The BSI intends to recommend the quantum-safe hybrid
key agreement mechanisms SecP256r1MLKEM768 and SecP384r1MLKEM1024
from the Internet-Draft at https:// datatracker.ietf.org/doc/
draft- ietf-tls-ecdhe-mlkem/ as soon as the corresponding RFC has
been adopted." [8] BSI TR-02102-1 (version 2026-01): "The quantum-
safe mechanisms recommended in this Technical Guideline are
generally not yet trusted to the same extent as the established
classical mechanisms, since they have not been as well studied
with regard to side-channel resistance and implementation
security. To ensure the long-term security of a key agreement,
this Technical Guideline therefore recommends the use of a hybrid
key agreement mechanism that combines a quantum- safe and a
classical mechanism. An obvious hybridization is to perform two
key agreements in parallel and to derive a combined key from the
generated key material." [9]
There are multiple significant warning signs.
I can only respond intermittently, and lack of response, even for
a longer time, does not mean endorsement. Currently, my resources
are outmatched by those of the NSA.
Deb Cooley (Sec AD):
On Tue, 07 July 2026 15:55 UTC [10]:
This is a public warning to the entire TLS working group, in
accordance
with RFC 3934 Section 2 [0]. [...]
*not participating in ad hominum attacks (veiled or unveiled)
*not sending multiple responses in quick succession
On Tue, 07 July 2026 17:37 UTC [11]:
I will only engage on a couple of points:
1. Obviously those participants who have been contributing in
good faith
have nothing to worry about.
2. The new participants should read the rules prior to posting,
this
warning will help them understand what is expected.
RFC 3934 Section 2 [12] explicitly states that a public warning is
the second step after communicating directly with the offending
individual: "Unless the disruptive behavior is severe enough that
it must be stopped immediately, the WG chair should attempt to
discourage the disruptive behavior by communicating directly with
the offending individual. If the behavior persists, the WG chair
should send at least one public warning on the WG mailing list."
I feel it necessary to seek clarification, since the warning and
the subsequent email referring to "[t]he new
participants" (plural) were issued shortly after I entered the
mailing list and someone accused me of an ad hominem attack,
although my point clearly concerned a potential conflict of
interest related to NSA activity on this mailing list, and, in
that context, specific actions (or failures to act) by NSA
employees [13].
Andrew Lee made a point [14] with which I agree and which I would
rephrase as follows: an indiscriminate warning can have an
intimidating effect and therefore is detrimental to an open
discussion. The same holds for any vagueness in the interpretation
of rules.
He also wrote:
*not sending multiple responses in quick succession
Participants on both sides have posted multiple messages
throughout this
WGLC. This standard has never previously been cited or enforced.
Further, this warning starves debate during a WGLC; whether that's
intentional or not doesn't matter.
To avoid intimidation and ensure the fair application of the
rules, all parties should strictly adhere to the RFCs and avoid
any uncertainty caused by vague wording.
My understanding is the following:
1. RFC 3934 Section 2 states that, in the case of disruptive
behavior, the WG (working group) chair should first contact the
individual directly. Ideally, the relevant passage should be
quoted and the reason explained.
2. RFC 3934 Section 2 states that a public warning should be
issued by the WG chair only as a second step, and the wording
implies that the individual should be identified in the public
warning (and also not to intimidate others).
3. RFC 3934 Section 2 states that neither individual
correspondence nor a public warning should be conducted by the AD
(Area Director), but by the WG chair.
4. RFC 3934 Section 2 does not state that "new participants"
should be greeted with a warning message.
5. The term "contributing in good faith" is subject to
interpretation, and in order to avoid intimidation, any person to
be warned should be mentioned by name instead. For example, not
only many researchers, but probably the majority of the world
population would reasonably question whether the pervasive NSA
presence in this working group qualifies as "contributing in good
faith."
6. Discussions about conflict of interest related to the NSA,
including their behavior on this mailing list with regard to a
potential conflict of interest - as NSA employees, not as members
of a specific ethnicity or some other outward property -
constitute neither an ad hominem attack nor some other violation
of any rule.
7. The criterion "not sending multiple responses in quick
succession" is not part of any RFC, as the RFCs define criteria
based on content rather than frequency (e.g., RFC 3683 Section 1
[15] mentions "unsolicited bulk e-mail" or "discussion of subjects
unrelated to IETF policy" etc.). (If a numerical criterion is
unavoidable, it should be exactly defined, e.g., more than two
emails per hour.) I find such a vague formulation problematic, as
I sometimes edit several emails in parallel, and later send them
at the same time, which would formally satisfy the criterion
"sending multiple responses in quick succession" although my
overall email volume is no higher than that of others.
8. An AD (Area Director) who has retired from the NSA after 35+
years no less than three years ago [16] and published RFC 9151 in
2022 as an NSA employee [17] would present a conflict of interest
when dealing with questions concerning the NSA, including whether
a debate constitutes a legitimate discussion of a conflict of
interest related to the NSA. In such a case, that AD should
therefore recuse themselves in accordance with RFC 7776 Section 7
(Conflicts of Interest) [18]: "Furthermore, a conflict of interest
arises if the person involved in the process of handling a
harassment report is closely associated personally or through
affiliation with any of the Reporter, Respondent, or Subject. /
For the avoidance of doubt, recusal in this context means
completely stepping out of any advisory or decision-making part of
any process associated with handling a harassment report, remedy
arising from a harassment report, or appeal into the handling of a
harassment report. That means that a recused person has no more
right to participate in or witness the process than any other
person from the community in the same situation." One example of a
potential conflict of interest is the publication of an RFC
authored solely by an NSA employee [17]. When NSA announced Suite
B Cryptography in 2005 and published the corresponding webpage in
2009 [19], the obvious strategy was to make the security levels of
128 bits of security (e.g., curve P-256) and 192 bits of security
(e.g., curve P-384) publicly available as Suite B, but withhold
the security level of 256 bits of security (e.g., curve P-521) as
part of Suite A [19, 20, 21]. (From the beginning, only AES-256
was used to "to enhance interoperability" [22], and in August
2015, the security level of 128 bits of security was removed
[23].) This may explain why RFC 9151 Section 5.1 [24] lists only
curve P-384 (192 bits of security) as the sole acceptable curve
without providing a rationale in Section 8 (Security
Considerations) [25] for this limitation. While providing a
minimum security (a lower bound) for commercial applications is a
legitimate concern, establishing a limitation (an upper bound) by
withholding 256 bits of security is not. RFC 8890 clearly says
"The Internet is for End Users" [26], and this means strong
cryptography (256 bits of security) should be available for
everyone. Notably, Bernstein explicitly praises curve P-521 (256
bits of security): "To be fair I should mention that there's one
standard NIST curve using a nice prime, namely 2^521−1" [27].
Please confirm this understanding or, if you disagree, provide an
explanation or clarification.
It would be helpful if every email received from the mailing list
included a permanent archive link in its signature, so that
participants do not have to search the archives manually when
quoting previous messages.
Kind regards,
Ken Kubota
____________________________________________________
Ken Kubota https://doi.org/10.4444/100
[1] https://mailarchive.ietf.org/arch/msg/
tls/5lGA_ObJ5Z58PqIRyF8nC3Lj1Po/
[2] https://www.rfc-editor.org/rfc/rfc9958.html#name-post-
quantum- and-traditiona
[3] https://groups.google.com/a/list.nist.gov/g/pqc-forum/c/
WFRDl8DqYQ4/m/o2XJ2YvfAwAJ
[4] https://nist.pqcrypto.org/foia/highlights.html
[5] https://www.rfc-editor.org/rfc/rfc9958.html#name-hybrid-key-
exchange-and-sig
[6] https://www.openssh.org/txt/release-9.0
[7] https://www.openssh.org/txt/release-10.4
[8] https://www.bsi.bund.de/SharedDocs/Downloads/EN/BSI/
Publications/TechGuidelines/TG02102/BSI-TR-02102-2.pdf?
__blob=publicationFile&v=11#page=12
[9] https://www.bsi.bund.de/SharedDocs/Downloads/EN/BSI/
Publications/TechGuidelines/TG02102/BSI-TR-02102-1.pdf?
__blob=publicationFile&v=14#page=29
[10] https://mailarchive.ietf.org/arch/msg/tls/hBFfH4lHo-
cLPNfikGfxkoV6hAY/
[11] https://mailarchive.ietf.org/arch/msg/tls/X44P3cF-H4s8kX-
RzyZEeQYTkbo/
[12] https://www.rfc-editor.org/rfc/rfc3934.html#section-2
[13] https://mailarchive.ietf.org/arch/msg/tls/
xTiYQnK8uS181kRlFe7xiFjdD20/
[14] https://mailarchive.ietf.org/arch/msg/tls/
LvUiinuyMPCXTFMrbeYB0aa1Iw4/
[15] https://www.rfc-editor.org/rfc/rfc3683.html#section-1
[16] https://datatracker.ietf.org/person/Deb%20Cooley "Deb Cooley
Pronouns: she/her
Retired Senior Cryptographic Vulnerability Analyst, National
Security Agency Cybersecurity Directorate (NSA/CSD) with 37+ years
of service in Dec 2023. Most of Deb’s career was spent as a
security evaluator on many different technologies including IP
encryptors, satellites, radios, and key management devices.
Previously, Special Government Expert for the Department of
Homeland Security, Cybersecurity and Infrastructure Security
Agency’s Cyber Security Division. Previously, acme working group
chair."
[17] https://www.rfc-editor.org/rfc/rfc9151.html "Published: April
2022 Author: D. Cooley NSA"
"Author's Address
Dorothy Cooley National Security Agency Email: [email protected]"
[18] https://www.rfc-editor.org/rfc/rfc7776.html#section-7
[19] https://web.archive.org/web/20090117004931/http://
www.nsa.gov/ ia/programs/suiteb_cryptography/index.shtml
[20] https://nvlpubs.nist.gov/nistpubs/Legacy/SP/
nistspecialpublication800-56ar.pdf#page=30
[21] https://csrc.nist.gov/files/pubs/fips/186-3/final/docs/
fips_186-3.pdf#page=101
[22] https://web.archive.org/web/20090117004931/http://
www.nsa.gov/ ia/programs/suiteb_cryptography/index.shtml "1.
CNSSP-15 correctly states that 192-bit AES keys are sufficient for
protecting even TOP SECRET information. However, Suite B uses only
256-bit keys to enhance interoperability."
[23] https://web.archive.org/web/20150815072948/https://
www.nsa.gov/ia/programs/suiteb_cryptography/index.shtml
[24] https://www.rfc-editor.org/rfc/rfc9151.html#section-5.1
[25] https://www.rfc-editor.org/rfc/rfc9151.html#section-8
[26] https://www.ietf.org/rfc/rfc8890.html
[27] https://web.archive.org/web/20260628050821/https://
blog.cr.yp.to/20140323-ecdsa.html
Am 07.07.2026 um 23:54 schrieb [email protected]
<[email protected]>:
The two independent layers is all about implementation, not
cryptography. If you look at the more detailed solutions that
implement two layers you'll see separate boxes with firewalls,
intrusion detection, etc. placed between them. That concept is
orthogonal to a discussion of multiple algorithms.
Get Outlook for Android
From: Ken Kubota <[email protected]> Sent: Tuesday, July 7, 2026
5:47:51 PM To: William Layton (GOV)
<[email protected]> Cc: [email protected] <[email protected]>
Subject: Re: [TLS] WG Last Call: draft-ietf-tls-mlkem-08 (Ends
2026-07-08)
Why the apparent change of position?
In this PDF document, the NSA consistently requires the exact
opposite:
a hybrid approach (two tunnels/layers).
"The security against a passive attack targeting Data in
Transit (DiT) across Public Black networks is provided by the
layered encryption of two independent tunnels (Inner and Outer)
using a specific selection of security protocols as instructed
in each CP. The two independent Encryption Components provide
confidentiality and high-level assurance for the solution,
because the adversary should never be able to exploit a single
cryptographic implementation to compromise both tunnels.
Two layers of Data at Rest (DAR) Commercial National Security
Algorithm (CNSA) encryption are employed to provide
confidentiality and mitigate passive attacks of stored data. The
DAR components are independent in a number of ways to mitigate
the ability of an adversary to exploit a single cryptographic
implementation to compromise both layers."
This document is available at:
https://web.archive.org/web/20260425180701/https://www.nsa.gov/
portals/75/documents/resources/everyone/csfc/threat-prevention.pdf
It is also still available on the NSA website.
Originally referenced in:
https://mailarchive.ietf.org/arch/msg/spasm/ytjNpbERE-YgKw-7c_w-
ZRUA1Fw/
The questions raised there remained unanswered:
https://mailarchive.ietf.org/arch/msg/spasm/
WJMl6inph8t8m898kcBzhpWZC0o/
Kind regards,
Ken Kubota
____________________________________________________
Ken Kubota https://doi.org/10.4444/100
Am 07.07.2026 um 22:08 schrieb [email protected]
<[email protected]>:
I support publication. Implementors will make their own
decisions. This algorithm choice
looks likely to be implemented in multiple places, so having
clear documentation of both security considerations and technical
details (as provided by the draft) is worthwhile for those who
might choose to use it.
-Bill _______________________________________________ TLS
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