David,

No text in 5280 requires name uniqueness across all CAs. It does require uniqueness on a per-CA basis (Section 4.1.2.6 of 5280). So, when two CAs with different parents are created with the same name, that is not a violation of 5280. The creation of
the doppelganger EE certs may violate 5280. The relevant text says:

The DN MUST be unique for each subject entity certified by _the one CA_ as defined
   by the issuer field.

The two CAs in my scenario have different parents, but the same name and same public key. So whether they are "the one CA" named in the issuer field is open to debate. I have modified
my text to avoid this issue.

As I explained, my description of an colluding CA attack differs from DKGs in that it is more general and thus. I think, more useful for discussion in the threat analysis.

Yes, it is true that CRLs and OCSP responses would not generally be tied to the two CA instances on different cert paths. But, that's not the point. It would be dangerous to assume that an RP can be confident that the revocation status data it acquires comes from a specific instance of a CA, when there are two CAs with the same names and same public keys. RFC 5280 does not provide implementation guidance that calls for pooling of revocation status info based on CA name. An RP may maintain a cache organized by cert path, associating revocation status info with each CA in each cert path. Such an implementation strategy is attractive because it can allow an RP to avoid redundant cert path validation processing when a target cert shares a portion of a cert path with other certs that have been validated. In such an implementation an RP would not be aware that there are two CAs with the same name on different cert paths, and revocation status data associated with each of these CAs would be acquired and maintained separately. In such
circumstances an attack of the sort I described is feasible.

Thus I stand by my analysis of the vulnerability, in the more general case.

Steve
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