Hi Deb,

Thanks a lot for your in-depth review, much appreciated!

We believe that all of your comments should be addressed in -20.

For the diff, see:
https://author-tools.ietf.org/iddiff?url2=draft-ietf-uta-tls13-iot-profile-20

cheers!

On Fri, 15 May 2026 at 16:01, Deb Cooley <[email protected]> wrote:
>
> Thank you for your work on this specification, apologies for taking so long 
> to send comments (I won't bore you with my excuses).
>
> I will happily take questions and/or comments on these.
>
> Deb Cooley
> Sec AD
>
> ---------------------------------------
> General:  If there are implementations which feel comfortable being listed, I 
> think it would be a good idea.  This could be in the shepherd's writeup or 
> you can add a section that would be removed by the RFC Editor before 
> publication (possibly in the 'discussion venue' section w/ a modified name).
>
> CA/Browser Forum:  There needs to be a stable reference for whatever you are 
> referring to when you say that the profile aligns or doesn't align with 
> something the CA/Browser Forum is specifying.
>
> Section 3:  Why isn't the 'Record Size Limit extension' not listed here?
>
> Section 8:  Add a sentence that states that this is out of scope at the 
> beginning of the section.  This way it is clear that RFC 9150 is not a 
> normative reference.
>
> Section 10, para 2:  How does the transmission of an ACK signal any sign of 
> disruption?  Isn't it the lack of an ACK that does that?
>
> Section 11:  RFC 7925 points to RFC 4086 which is pretty old at this point.  
> One could point to 8446bis, or if suitable RFC 8937.
>
> Section 17:  There is so much quoting of RFC 5280 (sometimes with a link, 
> sometimes not).  Is it really necessary?  Could you make a statement at the 
> beginning of the section, and only mention it when the profile deviates from 
> it?
>
> Section 17, para 3 and beyond:  Does this profile only handle entities that 
> have Device Identifiers?  Or are there other options?  If there are other 
> options, consider putting all the Device Identifier information in its own 
> section.
>
> Section 17, sentence after second set of bullets:  This sentence is 
> repetitive, I suggest deleting it.
>
> Section 17, second to last paragraph:  I struggle to see the point beyond 
> what the previous paragraph already makes.  If the point is that there are 
> many bootstrapping protocols, then perhaps say that.  I would move the 
> sentence about IDevIDs having a long lifetime up into the previous paragraph.
>
> Section 17, last paragraph:  I'm not entirely sure what the point is.  The 
> second sentence is way too long.  How about:  'However, this specification 
> does not claim conformance to IEEE 802.1AR which is broader, mandates 
> hardware, security, and process requirements outside IoT constraints.  This 
> profile borrows terminology and fields but intentionally omits those 
> operational requirements.'  Although I don't like 'operational' in my second 
> sentence since the first sentence doesn't use that term.  Maybe 'process 
> requirements?  Sentence 3 has the same issue... long enough that one loses 
> the plot before the end of the sentence.  Sentence 4, IDK, I lost the will to 
> live before this sentence.  I'd start over with a topic sentence, and a 
> couple of points.
>
> Section 17.1:  Remove the first phrase, 'to avoid repetition'. I'm not sure 
> what the last sentence note is supposed to convey, it only serves to make it 
> confusing - the first sentence says 'requirements on X.509 certificates', 
> does the rest need to be explained?
>
> Section 17.1.2:  Not quite.  RFC 5280 does not require non-sequential serial 
> numbers, it only requires them to be unique for a given CA.  I would delete 
> the last paragraph.
>
> Section 17.1.3, 17.1.6, last sentence: What is the advantage of using the 
> same signature algorithm for both CAs and devices?  Under what circumstances 
> might one violate the 'SHOULD'?  [note:  in my opinion, this SHOULD makes it 
> harder to transition later, one has to update the CAs and then the devices 
> which increases the timeline.]
>
> Section 17.1.5:  Please make it clear that if one uses the concept of 
> 'unlimited lifetime' that this applies to the whole trust chain - from the 
> trust anchor (Root CA) down to the subordinate CAs.
>
> Section 17.1.7:  This comment can be summarized as 'don't bury the lede':  
> Para 1 and 2 - separate the background sentences from the 
> requirement/guidance sentences.  Reworking some of these sentences to be 
> shorter and more concise would be a good idea.  Para 3, where to start...   
> Remove 'has also seen considerable uptake...', 'some of which are 
> standardized'.  Sentence 4 'device management protocols...' should be the 
> first sentence.  Make 'Certificate upsdates do not affect existing...' to the 
> end a new paragraph (since it has nothing to do with short cert lifetimes).  
> Last para:  should be up front in the section (without the 'hence').
>
> Section 17.2.4:  So, if keyCertSign or cRLSign MUST be set, but there is no 
> Key Usage extension (since it is apparently optional - SHOULD), how does that 
> work?  Possibly outlining when/why one might choose to not have a keyusage 
> extension might be a good step.  Is DS required for the Root CA certificate?
>
> Section 17.2.5:  Let me understand this, a Root certificate is permitted to 
> have no expiry, and no limit for the depth of the CA chain.
>
> Section 17.4.1, last para:  Does this actually pertain to the end-entity 
> certificate?  I suspect this needs to be moved to a more appropriate section, 
> if it needs to be stated at all (how often is an IOT device a TLS server?)
>
> Section 17.4.4, para 2:  I don't believe that this is how it works.  If the 
> private key associated with the cert is meant to be used for 
> authentication/signature, then DS is the appropriate KE.  If the private key 
> is used to enable encryption (typically keyEncipherment or keyAgreement), 
> then those are set.  Typically, one would discourage the use of a single 
> private key for both DS and keyEncipherment/keyAgreement uses.  Delivery of 
> the private key to the device is a whole different matter.  This part should 
> be removed from this section and covered elsewhere (if it is necessary to 
> cover it at all).
>
> Section 17.4.4, para 3:  Given the current kerfluffle in the CA/B Forum (or 
> maybe within Google), is it still the plan to include id-kp-clientAuth?
>
> Section 20, last para:  TLS 1.2?  Is it a typo?
>
> Section 22:  You will want to make sure that this is informational.  Maybe 
> add a sentence to state that this section is guidance vice requirements.
>
> Section 23:  What if certificates are posted instead of transmitted within 
> the TLS exchange?  Consider if there needs to be a mention of the privacy 
> situation when that option is considered (Section 19)
>
> Section 24:  I do think there needs to be a discussion of the pros/cons of a 
> Root certificate that never expires.  That discussion could be here, or in 
> Section 17.2.5 (I don't see it there currently).
>
> References:  RFC 4210 has been obsoleted by RFC 9810 (note RFC 4210 is ref 
> multiple times within the draft).  There are a couple of others which have 
> either been issued, or are in Auth48 (8446bis, for example).

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