Ben,

6962 and 6962-bis are compliant with 5280. The ASN.1 structure that is included is an OCTET STRING. The value of that OCTET STRING is the TLS structure.
the use of OCTET STRING is only superficially compliant; it is inconsistent with all of the prior X.509 extensions of which I am aware, and with the text that Russ Housley cited in his message on 3/3. Rob's observation about what X.680 says is not relevant to this debate: the issue is not what an OCTET STRING is allowed to contain in general, but what is the syntax
of an X.509 extension.

The alternatives are:

a) Encode SCTs different ways for different contexts. This seems like pointless complexity.
to me it seems entirely appropriate.

b) Change SCTs to ASN.1 structures, and wrap these in a TLS opaque when presented in a TLS extension. This is exactly analogous to the current situation, and analogous arguments can be made for/against it.
I agree that this is unattractive.
I hope no-one is arguing for a), leaving us with b), and no convincing reason to choose it over the current format on the basis of what the standards say (or vice versa), as far as I can see.
I am arguing for a).
Given that since Jan 1 2015 significant numbers of certificates have been deployed using the existing format, I suggest that the appropriate resolution is to continue with the format that is already deployed.
Experience gained with 6269 is relevant, as it presumably shows that implementers have been able to make the current syntax work. But, an experimental RFC represent does not establish a precedent relevant to a standards track RFC that precedes it. In many (most?) cases Experimental RFCs receive little review before being published. If the IETF were to agree that implementations based on such RFCs establish design precedents for standards track RFCs, especially when they conflict with existing, standards track RFCs, this would encourage publication
of experimental RFCs as a way to game the system.

Steve

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