[cabfpub] Proposed new ballot on IP Addresses in SANs

Thu Apr 21 19:48:55 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.
[JR] Wildcard FQDNs are not defined. Wildcard certs are.  Although I do
think wildcards characters should be limited to the left most label, what is
understood is largely irrelevant. The langue matters and what the BRs say is
definitely ambiguous and unclear. 

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.  
[JR] Pretty sure that's the nature of any industry standards body. Plus, I
think its incorrect to assume that anyone with a different interpretation of
a section is willfully looking for loopholes. Precise language in any
standard is important, especially when you consider that non-native English
speakers are reviewing the document. In any event, if everyone agreed with
interpretation, amending guidelines for language clarity should be a simple
task.  Clearly Symantec interpreted the requirement differently than Comodo
or DigiCert. However, given the language, I can't agree that the certs are
being mis-issued. 

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.

[JR] Which is why I'm petitioning to modify the requirements now. We have a
definite use case where they are required by a major browser.  I'd like to
see that accommodated. What happens with the certs issued prior to changing
the requirements, as always, is up to the browsers. The CAB Forum has never
had an enforcement mechanism. Without the browsers adoption, the guidelines
are merely advisory. The EV processing document for example.

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  <mailto:richard.smith at comodo.com> <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
<https://crt.sh/?cablint=65&iCAID=1449&opt=cablint> &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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