[cabfpub] Proposed new ballot on IP Addresses in SANs

Rich Smith richard.smith at comodo.com
Thu Apr 21 18:44:19 UTC 2016

In the SAN section of the BRs it simply says, "Wildcard FQDNs are 
permitted."  To know WHAT is permitted you MUST look to the definition, 
and the definition clearly states "...left most position..."  Clearly 
these certificates are non-compliant.  And I don't buy for second that 
that's not understood by anyone who has participated in Forum 
discussions for any length of time.

And have we devolved to the point that we're now creating and editing 
requirements only to then go forth and have a competition to see which 
CA can out-do the others in finding loopholes in them?  Is that what 
this Forum has become?  If so, then what are we doing here?  Let's 
shutter the place and walk away.

The IP address certs that started this discussion aren't even a 
loophole.  They are specifically and clearly non-compliant.  Now I'm not 
a lawyer, but I do view the action of issuing them as anti-competitive.  
I've had specific cases wherein I couldn't issue EV certificates to 
labor unions in the U.S. for YEARS because the wording in the EV 
Guidelines at the time did not allow for them.  I came here, I advised 
the Forum of my plight, and asked for a solution.  No one disagreed that 
they clearly legally existed as an organization, but the solution was 
caught up in haggling over minutiae for YEARS before a suitable change 
to the Guidelines was officially adopted.  I didn't just go ahead and 
issue the certificates anyway, I waited for the Forum to arrive at a 
consensus and fix the problem.  And as a participant in good faith here, 
that's what I expect of other participants.


On 4/21/2016 12:54 PM, Jeremy Rowley wrote:
> We don't issue these certs, but the section cited does not sat you 
> can't issue them. That is only a definition of a wildcard cert.
> Rich Smith <richard.smith at comodo.com> wrote:
> I share Ryan's concerns.  I find it deeply troubling that a member of 
> this Forum, whose representative is the current Forum Chair, and which 
> had no small part in drafting the BRs and seeing them through to 
> adoption is willfully issuing certificates in direct contravention of 
> the Requirements.  None of us is perfect, but as head of validation 
> for Comodo I make every effort to ensure that certificates issued by 
> Comodo are fully compliant with the BRs and EV Guidelines, business 
> expediency notwithstanding.
> In checking through certlint to try to find certificates issued with 
> improperly formatted IP addresses, in order that I might better 
> understand this issue, imagine my surprise to find several wildcard 
> certificates, also issued by Symantec, and also in direct 
> contravention of the BRs:
> lab-rct-*.us.kworld.kpmg.com
> lab-rct-*.us.kpmg.com
> rct-*.us.kpmg.com
> See: https://crt.sh/?cablint=65&iCAID=1449&opt=cablint
> The BRs state, in definitions section:
> *Wildcard Certificate:* A Certificate containing an asterisk (*) in 
> the *left-most position* /[emphasis mine] /of any of the Subject 
> Fully-Qualified Domain Names contained in the Certificate.
> Regards,
> Rich Smith
> Validation Manager
> Comodo
> On 4/21/2016 8:23 AM, Ryan Sleevi wrote:
>> On Thu, Apr 21, 2016 at 6:13 AM, Jody Cloutier <jodycl at microsoft.com 
>> <mailto:jodycl at microsoft.com>> wrote:
>>     Ryan, I'm not sure I understand why Google is so intent on this
>>     new course of public shaming on this matter and others currently
>>     under discussion, but if it helps to do the right thing, then
>>     fine. The fact is that the requirement was not addressed, and we
>>     need to figure out how to fix the issue for all of our customers.
>>     Microsoft has addressed this in Windows 10, but we are not
>>     currently planning on back-porting this change to previous
>>     operating systems. As such, this change is needed or all of our
>>     customers will be affected.
>> Jody,
>> Symantec has 8 months to investigate a solution that doesn't require 
>> violating the BRs nor require violating RFC 5280. They've admitted, 
>> by Rick, that they've instead chosen to continue to violate the BRs, 
>> and are looking to change the BRs to retroactively make this 
>> behaviour acceptable. That is unquestionably deserving of censure, on 
>> its own merits, regardless of the option.
>> Had Symantec shown that the solution provided to them - which would 
>> have functioned properly for all Microsoft users - was not in fact 
>> viable, in a timely fashion, and for reasons they could explain, 
>> that's certainly worthy of consideration. But that's clearly not the 
>> case here, and that's unacceptable behaviour for a publicly trusted CA.
>> The burden of demonstrating why the proposed solution doesn't work 
>> should exist with Symantec: They're the only one that can speak to 
>> their customers needs, they're the only ones who can investigate the 
>> technical viability (as a publicly trusted CA), and they're the only 
>> ones who can speak as to why such a solution may not be possible. If 
>> the reasons are "because we don't want to", that should seriously 
>> inform the response to a ballot, but if there are reasons such as 
>> "This doesn't work for reason X", then that could be a meaningfully 
>> compelling reason.
>> However, the idea that a Forum member would actively, intentionally, 
>> and knowingly violate the BRs in order that they may continue to sell 
>> certificates to customers, participating in defining standards that 
>> their competitors are obligated to follow but which they themselves 
>> do not intend to, and potentially profiting off the customers for 
>> which their competitors are obligated to refuse but for which they 
>> will clearly accept (in contravention of the BRs), speaks seriously 
>> to acting in bad faith and in an anti-competitive manner. And that's 
>> deeply troubling.
>> To be clear: The censure is for the behaviour, not for the proposal. 
>> Given that this proposal was raised in the past, addressed in the 
>> past, and in the 8 months sense, either no good-faith effort was put 
>> forward OR no good-faith effort is communicated, is a serious and 
>> egregious breach of public trust, and thus deserving of strong and 
>> direct response, because if that pattern is practiced and encouraged, 
>> it undermines and eliminates any value in the Forum itself.
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