[cabfpub] Ballot 117 - EV Code Signing Guidelines Corrections

Rob Stradling rob.stradling at comodo.com
Mon Mar 24 14:19:56 UTC 2014

On 21/03/14 19:08, Ben Wilson wrote:
> Did Comodo object to / or vote against the EV Code Signing Guidelines in the
> past?

No.  We chaired the original working group that drafted v1 of the EV 
Code Signing Guidelines.  We were, and continue to be, strong supporters 
of the concept of EV Code Signing.

However, we also want to protect the CABForum from antitrust concerns.

> If this is the first we've heard of this concern on code signing,
> then my question is why should we hold up this vote, which from my
> perspective has been presented as a very minor issue?

On a purely technical level, yes, it's a very minor issue.  But, as we 
explained when we voted, our concerns are not of a technical nature.

> Why use a hammer?

If the only tool left in your toolbox is a hammer, every problem looks 
like a nail.

> If this was merely a bow shot, then this issue needs to take on its own
> independent form and be discussed as an entirely new topic, and a new thread
> should be started.  If Comodo wants us to examine our scope of action in
> greater depth, then I think it needs to set forth its analysis separately in
> a detailed explanation.  Voting started last Monday when the comment period
> ended, and my understanding is that we generally try to refrain from
> presenting arguments against when we are near the end of the voting period.
> That's my 2 cents.
> -----Original Message-----
> From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On
> Behalf Of Moudrick M. Dadashov
> Sent: Friday, March 21, 2014 12:39 PM
> To: Rob Stradling; ben at digicert.com; public at cabforum.org
> Subject: Re: [cabfpub] Ballot 117 - EV Code Signing Guidelines Corrections
> Hi,
> I think Rob's comment raises potentially problematic practice.
> I'm not sure about the voting procedure, but I'd suggest we find some ways
> to discuss these issues before the end of voting period.
> Is this possible?
> Thanks,
> M.D.
> On 3/21/2014 4:40 PM, Rob Stradling wrote:
>> Comodo votes "no".
>> Comodo strongly supports the concept of EV Code Signing, and would
>> very much like to see wider implementation and participation.
>> However, as far as we are aware, EV Code Signing has been implemented
>> by only a single vendor with only two CA participants in that vendor's
> program.
>> Therefore, as Section 1.2 of the Bylaws of the CA/B Forum states that
>> the purpose of the Forum is to meet and discuss matters of common
>> interest, we do not believe the EV Code Signing Guidelines to be a
>> matter of common interest for the Forum at this time.  Specifically,
>> absent wider implementation and participation in the use of this
>> standard, additional work now by the CA/B Forum on this topic will be
>> in contravention of Section 1.2 of the Bylaws.
>> Moreover, Section 1.3 of the Bylaws of the CA/B Forum states that
>> Forum Members shall not use their participation in the Forum either to
>> promote their own products and offerings or to restrict or impede the
>> products and offerings of other Members.  Given the current level of
>> implementation and participation in EV Code Signing, Comodo currently
>> cannot vote in favour of Ballot 117, because agreements,
>> understandings, or protocols reached in the context of standard
>> setting efforts may violate antitrust laws if the effective result of
>> such efforts is to restrain competition.
>> On 10/03/14 16:24, Ben Wilson wrote:
>>> Ballot 117 - EV Code Signing Guidelines Corrections
>>> Jeremy Rowley of DigiCert made the following motion, and Iñigo
>>> Barreira of Izenpe and Rick Andrews of Symantec endorsed it.
>>> There are two issues with the EV code signing guidelines that need
>>> correction:
>>> 1.  Section 9.2.2 of the EV code signing guidelines recommends that
>>> CAs not include the SAN extension in an EV certificate.  However,
>>> section
>>> 9.7 requires that an EV certificate include
>>> subjectAltName:permanentIdentifier. Because the main concern is that
>>> a CA might include a domain name in the SAN extension, we should
>>> specify that this practice is not allowed and recognize that other
>>> information may be present.
>>> 2.  Because the EV Code Signing Guidelines were originally based on
>>> the EV Guidelines for SSL, Section 9.2.3 of the EV code signing
>>> guidelines deprecates the CN field.  However, the CABF Code Signing
>>> Working Group received a report that this field is still required by
>>> code signing applications. We should still include the CN in code
>>> signing certificates for the Subscriber’s legal name, even though the
>>> field is deprecated for use in SSL/TLS certificates.
>>> ---Motion Begins---
>>> Effective immediately:
>>> a.            Replace section 9.2.2 with the following:
>>> “9.2.2    Subject Alternative Name Extension
>>> This field MUST be present and MUST contain the permanentIdentifier
>>> specified in Section 9.7. This field MUST NOT contain a Domain Name
>>> or IP Address.”
>>> b.            Amend section 9.2.3 as follows:
>>> “9.2.2    Subject Common Name Field
>>> Certificate field: subject:commonName (OID
>>> Required/Optional: Required
>>> Contents: This field MUST contain the Subject’s legal name as
>>> verified under Section 11.2.“
>>> ---Motion ends---
>>> Motion Ends
>>> The review period for this ballot shall commence at 2200 UTC on
>>> Monday,
>>> 10 March 2014, and will close at 2200 UTC on Monday, 17 March 2014.
>>> Unless the motion is withdrawn during the review period, the voting
>>> period will start immediately thereafter and will close at 2200 UTC
>>> on Monday, 24 March 2014.
>>> Votes must be cast by posting an on-list reply to this thread.
>>> A vote in favor of the motion must indicate a clear 'yes' in the
> response.
>>> A vote against must indicate a clear 'no' in the response.
>>> A vote to abstain must indicate a clear 'abstain' in the response.
>>> Unclear responses will not be counted.
>>> The latest vote received from any representative of a voting member
>>> before the close of the voting period will be counted.
>>> Voting members are listed here: https://cabforum.org/members/
>>> In order for the motion to be adopted, two thirds or more of the
>>> votes cast by members in the CA category and more than one half of
>>> the votes cast by members in the browser category must be in favor.
>>> Quorum is currently six (6) members– at least six members must
>>> participate in the ballot, either by voting in favor, voting against,
>>> or by abstaining for the vote to be valid.

Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online
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