Ben,

... Ok, that's what _you_ do, but 5280 describes a long list of cert path validation rules

    and your doc just says that these can be relaxed. It does not
    prohibit a log from
    performing  the full set dictated by PKIX and X.509 path
    validation procedures, nor
    does it provide guidance of which subset SHOULD/MUST be performed.
    Absent such guidance
    different log operators can legitimately perform different checks,
    resulting in chaos.


I don't believe it will result in chaos, but anyway, the purpose of checking signatures on log submissions is to combat spam. I don't think we should tightly define exactly what checks are performed to that end, because that's a great way to leave yourself unable to defend against some kind of unforeseen spam. We can certainly clarify that. I've added a ticket.
Perhaps I have not been clear enough in specifying my concern. A CA (or cert Subject) submitting a cert chain to a log needs to know, unambiguously, what checks will be performed. This specificity is needed to ensure that submissions to multiple logs will all be accepted or rejected (assuming that the root CA for the chain is advertised as acceptable by the log operator).

    ...
    If we had a agreed-upon  requirements doc that explained why the
    serial number is
    critical, and if it discussed the impact on CAs that may use
    serial number management
    techniques that preclude pre-determining the serial number
    assigned to a cert, then
    we would be in good shape. But we don't. So, I think we may have a
    serious problem
    with this aspect of the precert model.


The purpose of CT is to detect mis-issuance so that it can be rectified. As already explained, some revocation mechanisms require the serial number of the revoked cert. I don\t think we need a separate requirements doc for it to be obvious that without the serial number, we have a problem.
I think we do need a document that specifies what remediation mechanisms are required. I saw no reference to revocation in the doc. Some list members have speculated that CT is a reputation mechanism, and a recent response from you supported that notion. A reputation mechanism need not make use of revocation as per X.509 mechanisms. For example, one might have an auditor distribute a list of "bad" certs to clients, where the public key was the means of identifying the bad cert. I agree that one remediation mechanism calls for the issuing CA to put a detected, bad cert onto a CRL. But, that presumes that the mis-issuance was an error or the result of an attack. Since there is no attack model for CT, I don't know if that is the only sort of mis-issuance event it is supposed to counter.

    ...
    "Compliant" with what set of specs? I noted an aspect of a design
    for a CA-focused
    HSM that, for several years, was used by VeriSign to issue every
    cert. It is a powerful
    feature for high assurance cert issuance. It is also incompatible
    with the precert design.
    The precert design seems to preclude use of some approaches to
    serial number management
    that may reduce CA secruity. Thus it appears to be a tradeoff, one
    that this WG has not
    discussed. Please describe what you mean by a "complaint" CA.


I do not believe that the use of an HSM in any way constrains a CA's ability to deal with serial numbers as needed. The issue of compliance is a red herring.
You introduced the term "complaint" into this issue, not me, so if it is a red herring, it's yours! More to the point, I identified a legitimate way for HSMs to operate, to reduce the vulnerability of a CA to the sort of attack that DigiNotar experienced. And, that model of operation has been used by large CAs in the past. Your offhand dismissal of this issue is inappropriate. In essence you are saying that Google has developed a rough model of how to make CT work and CAs need to 'make changes to their operational processes, and to software and maybe hardware, to accommodate
your model. This is an inappropriate mindset for working in the IETF.

    ...


Precerts are critical because otherwise server s/w has to be updated to deliver SCTs to clients. We know that isn't going to happen universally any time soon. I agree the I-D should mention this.
So, the designer have decided that it is appropriate to require CAs to change their software, rather than asking server software developers to change theirs. I acknowledge that there are more servers in operation than CAs, but that's not really the right metric. The issue is how many sources of server software are used by the vast majority of servers. I'm guessing that that number is small, especially compared to the number of CAs, many of which have had to write all or most of their provisining software. This is a critical design decision that ought to be articulated in the document, and agreed upon by the WG, not just the CT design team.

Steve
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