[cabfcert_policy] Amend BR subsections 7.1.4.2.2 d/e

Fri Jun 3 06:56:24 MST 2016

I don’t support making the field optional if it there is no appropriate value.  It makes it impossible to distinguish between fields that were intentionally omitted and those that were omitted by mistake.

I support previous proposals along these lines that follow the common existing practice of simply repeating the name of the country as the state/locality in these cases, or perhaps we could agree on some other appropriate value like “not applicable”.

-Tim

From: policyreview-bounces at cabforum.org [mailto:policyreview-bounces at cabforum.org] On Behalf Of ???
Sent: Friday, June 03, 2016 6:56 AM
To: 'Rick Andrews'; 'Jeremy Rowley'; validation at cabforum.org; Peter Bowen; 'Rob Stradling'; policyreview at cabforum.org
Cc: Dean Coclin; 王文正; Kirk Hall
Subject: [cabfcert_policy] Amend BR subsections 7.1.4.2.2 d/e

Dear All,

     As yesterday’s validation working group phone call discussion about DN in small countries such as Singapore and Taiwan. I resend some discussions after Certificate Policy working group mailing list  phone call, Bugzilla and discussion in 33rd F2F meeting (as attached file) as below.
After  discussions, we will write a pre-ballot to fix the issue.

     We suggest to amend BR 7.1.4.2.2 d/e.

Li-Chun CHEN<mailto:lcchen.cissp at gmail.com> 2016-02-05 01:29:17 MST
After discussion in Chunghwa Telecom, Dr. Wen-Cheng Wang suggests to amend subsections 7.1.4.2.2 d/e as below:

d.    Certificate Field: subject:localityName (OID: 2.5.4.7)
Required if the subject:organizationName field is present and the subject:stateOrProvinceName field is absent.
Optional if: (a) the subject:organizationName and subject:stateOrProvinceName fields are present, or (b) if the
subject:organizationName and subject:countryName fields are present and the country/jurisdiction specified by the
subject:countryName field has a centralized registry for that kind of organizations so that the
organization name specified by the subject:organizationName field is "unique" in the entire country/jurisdiction.
Normally, situation (b) may exist in small countries/jurisdictions such as Singapore (SG), Taiwan (TW), etc.

e.    Certificate Field: subject:stateOrProvinceName (OID: 2.5.4.8)
Required if the subject:organizationName field is present and subject:localityName field is absent.
Optional if: (a) the subject:organizationName and subject:stateOrProvinceName fields are present, or (b) if the
subject:organizationName and subject:countryName fields are present and the country/jurisdiction specified by the
subject:countryName field has a centralized registry for that kind of organizations so that the
organization name specified by the subject:organizationName field is "unique" in the entire country/jurisdiction.
Normally, situation (b) may exist in small countries/jurisdictions such as Singapore (SG), Taiwan (TW), etc.

      As for Peter, he e-mailed that
I think there is a misunderstanding.  The address represented in the certificate by the plain localityName and stateOrProvinceName attributes is the Applicant’s address of existence or operation, not their jurisdiction of incorporation.  The BRs note that a utility bill or bank statement can be used to verify the address.

For example, https://crt.sh/?id=11206357&opt=cablint<http://scanmail.trustwave.com/?c=4062&d=_uDR1yQtxBmbcaOy6vts1Cc44on0C-TAgLmQujutew&s=5&u=https%3a%2f%2fcrt%2esh%2f%3fid%3d11206357%26opt%3dcablint> shows that the FQDN is www.fenton.com.tw<http://scanmail.trustwave.com/?c=4062&d=_uDR1yQtxBmbcaOy6vts1Cc44on0C-TAgOzA5Wr_KA&s=5&u=http%3a%2f%2fwww%2efenton%2ecom%2etw>. The contact information provided on the website (http://www.fenton.com.tw/index.php?route=information/contact<http://scanmail.trustwave.com/?c=4062&d=_uDR1yQtxBmbcaOy6vts1Cc44on0C-TAgL_DuT7zLA&s=5&u=http%3a%2f%2fwww%2efenton%2ecom%2etw%2findex%2ephp%3froute%3dinformation%2fcontact>) is 高雄市新興區民權一路251號24樓之2.  Assuming you verify that this is the address of the applicant, then you could include 高雄市 (or Kaohsiung) in the localityName or stateOrProvinceName field.

I don’t think there is any need to update the BRs for this case.

      But I have to say that  高雄市 (or Kaohsiung) should be  in the localityName field. There is no State or Province in Taiwan for高雄市(or Kaohsiung).

     And Dr. Wen-Cheng Wang has replied to Peter as below:

   We know that the current BR tends to interpret the localityName and stateOrProvinceName attributes as identifying the subject’s address of existence or operation. However, to enforce this kind of interpretation and require the Subject DN must at least contain either the localityName and stateOrProvinceName attributes may cause problem in some situations, especially in some small country where organizations are allowed to be registered at country-level. For example, in Taiwan, a corporation can be registered at country-level but can also be register at city/county-level. If there is a country-level corporation named “Farmer’s Association” of which physical address is located in Taipei City, with current Subject DN rule of BR, its Subject DN will be “C=TW, L=Taipei City, O=Farmer’s Association”. However, if there is also a city/county-level “Farmer’s Association” in Taipei City, its Subject DN will also be “C=TW, L=Taipei City, O=Farmer’s Association”. How do you distinguish them by DN?

I do not understand why we need to enforce require the Subject DN must at least contain either the localityName and stateOrProvinceName attributes if the registered organizational name of a country-level corporation/organization is already guaranteed to be unique under the country name?

The following diagram is taken from Annex B of ITU-T X.521 (Suggested name form and Directory information tree structures). Please note path 1 -> 3, it suggests that there is no need to include a Locality attribute in the directory name of a country-level organization.
[cid:image001.png at 01D169D3.5ED33150]

Sincerely Yours,

        Li-Chun CHEN
        Chunghwa Telecom Co. Ltd.

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