[cabfpub] Verification of Legal Existence Ballot

Ryan Sleevi sleevi at google.com
Thu May 14 17:31:25 UTC 2015

Thanks Jeremy for circulating this.

I've tried to respond inline below - I hope this doesn't screw up archive

On Thu, May 14, 2015 at 8:50 AM, Jeremy Rowley <jeremy.rowley at digicert.com>

>  (2) *Government Entity Subjects*: *Unless verified under subsection (6),
> * all items listed in Section 11.2.1(2) MUST either be verified directly
> with, or obtained directly from, one of the following: (i) a Qualified
> Government Information Source in the political subdivision in which such
> Government Entity operates; (ii) a superior governing Government Entity in
> the same political subdivision as the Applicant (e.g. a Secretary of State
> may verify the legal existence of a specific State Department), or (iii)
> from a judge that is an active member of the federal, state or local
> judiciary within that political subdivision, or (iv) an attorney
> representing the Government Entity.

This modification does seem to lead to a weaker, more lax requirement
compared to the existing language. That is, with the new definition of
Verified Professional Letter, the Accountant or Legal Opinion may be from
an entity different than the Government Entity (or so it seems).

I didn't see where this requirement was preserved, and perhaps it's there
in intent, but not letter.

This also changes the set of acceptable documents from being a "Verified
Legal Opinion" to *also* accepting a Verified Accountant Letter for this
validation. Is that intentional? What are the implications here of adding
another means to verify for government entity subjects?

>  (B) Obtaining an Independent Confirmation From the Applicant (as
> described in Section 11.10.4), or a *Verified Professional Letter* Verified
> Legal Opinion (as described in Section 11.10.1), or a Verified Accountant
> Letter (as described in Section 11.10.2) verifying that the Contract
> Signer and/or the Certificate Approver, as applicable, is either an
> employee or has otherwise been appointed as an agent of the Applicant.

This change (and related) all strike mention of Sections 11.10.1/11.10.2,
and the new definitional introduction of Verified Professional Letter
doesn't strictly establish that the Verified Legal Opinion / Verified
Accountant Letter must comply with the requirements.

This is arguably a pedantic distinction, since it should be "obvious" that
Sections 11.10.1/11.10.2 apply, but it's worth highlighting that it is a
semantic change. (Yes, a number of other sections referred to Verified
Legal Opinion/Verified Accountant Letter w/o referring to the section
cross-reference, but now we have *nothing* that cross-references, if this
ballot goes forward)
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