First off, I have a general comment that there seem to be some places in
the document where it is implicitly assumed that the HTTPS client and
server trust each other to behave correctly and are "only" truing to
detect misbehavior by other parties (i.e., CAs or parties subverting the
CA infrastructure, etc.), to the exclusion of having the client and server
retain some level of distrust or sanity checking of each other.  I'm not
sure that the client wants to always trust the server, given that the
scheme is positing a universe where some clients will sometimes
successfully connect to hostile servers supplied with fraudulent
certificates (that validate) by the attacker.

In a related vein, in 3.1.2, should the server be allowed to exclude SCTs
that it considers legitimate?  What are the consequences if the server
misbehaves and shares "other data that they may learn from the submission
of SCTs by HTTP clients"?

I'm also a little confused by the last paragraph of 3.1.2, "the selection
MUST NOT be influenced by potential HTTPS clients connecting directly to
the auditor".  It seems like the only risk of allowing a client to request
monitoring for a given site is additional resource usage by the server
(assuming the client is aware of the privacy considerations of making such
a request).  I suspect that there is a valid concern here, but the text as
written may be overly broad.

I seem to be missing a normative reference for various terminology and
conventions (e.g., "the timestamp, as a number", which I assume is
milliseconds since the epoch, excluding leap seconds, in decimal, to match
the other specs).

The formatting in 4.1.3 seems funky; it looks like a list has been
condensed into running text (including bullet symbols)

-Ben

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