<div dir="ltr"><div>Hi Ryan,</div><div><br></div><div>I have updated the ballot using your first suggested sentence, "Effective 2021-10-01, for validation of Domain Names and IP
Addresses according to Section 3.2.2.4 and 3.2.2.5, any reused data,
document, or completed validation MUST be obtained no more than 398 days
prior to issuing the Certificate." <br></div><div><br></div><div>It would be good to fix EVG section 11.14.1(6), but I'd like to get the ballot passed as soon as possible. I'll resubmit the revised version shortly for discussion. <br></div><div><br></div><div>Here is the immutable link: <a href="https://github.com/cabforum/servercert/compare/9672b03bec91ad9a80f826e928e47f5c1f82964b...7cd105daf3baba01579c167d9fc10afacd49c503">https://github.com/cabforum/servercert/compare/9672b03bec91ad9a80f826e928e47f5c1f82964b...7cd105daf3baba01579c167d9fc10afacd49c503</a></div><div><br></div><div><br></div>
</div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Thu, Apr 1, 2021 at 2:10 PM Ryan Sleevi <<a href="mailto:sleevi@google.com">sleevi@google.com</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex"><div dir="ltr"><div>Ballot bookkeeping side: Hopefully once we get SC41 merged, we'll be able to open this as a pull request against the CA/B Forum repo and comment inline. I'll try to find out why <a href="https://github.com/cabforum/servercert/compare/SC41...BenWilson-Mozilla:398-day-FQDN-validation" target="_blank">https://github.com/cabforum/servercert/compare/SC41...BenWilson-Mozilla:398-day-FQDN-validation</a> is suggesting it's a dirty merge - and try to make sure this doesn't impact the ballot.</div><div><br></div>In Section 4.2.1, you have the following language:<br>"Effective 2021-10-01, the CA SHALL verify Domain Names and IP Addresses no more than 398 days prior to Certificate issuance."<div><br></div><div>This might be read ambiguously, since the previous paragraph seems to suggest that reuse is, in fact, accepted as "verifying". While that's plainly not the intent, what do you think about:</div><div><br></div><div>"Effective 2021-10-01, for validation of Domain Names and IP Addresses according to Section 3.2.2.4 and 3.2.2.5, any reused data, document, or completed validation MUST be obtained no more than 398 days prior to issuing the Certificate."</div><div><br></div><div>Feels a little clunky, but perhaps fits in better. We could try rephrasing the whole paragraph, but that seems a bit of a heavier task for this ballot. But framing it in terms of reuse, since that's what this paragraph talks about, seems to work better.</div><div><br></div><div>There's also the unfortunate issue of a CA interpreting "398 days and an hour" to be "398 days" rather than "399 days". I'm not sure if we want to try to tackle that here, but just acknowledging this used to be an issue in the past that caused CA incidents. We could slap an "exactly" before 398 days, but that also feels like it might be superfluous. </div><div><br></div><div>Alternatively, a different approach would be to change the sentence to: "Effective 2021-10-01, the maximum time permitted for reuse of data, documents, and/or prior validations for demonstrations of domain control and IP addresses, as specified in [Section 3.2.2.4](#3224-validation-of-domain-authorization-or-control) and [Section 3.2.2.5](#3225-authentication-for-an-ip-address), SHALL be 398 days". This would then naturally flow with the next paragraph's restriction.</div><div><br></div><div>The changes to the EVG look fine, but note that they'll practically have no effect, because of the preceding paragraph ("Except for reissuance" creating the validation-carveout). I'm not sure if you want to tackle 11.14.1 (6). I think these are important to tackle, which is why I'd previously tried to fix these up so that the EVGs don't appear to override/ignore the BRs. However, it is a bit trickier. As it reads now, it may be seen as having loopholes, so I'm curious if you're open for more discussion and proposals to try to close those.</div></div>
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