[cabfpub] Naming rules

Tue Mar 28 03:03:52 MST 2017

Hi, Dimitris,

    Thank you for your comment about BRs 3.2.2.1. 

    Because some discussion was in CP reviewing WG discussion list, maybe it is suitable to quote in the public list for others to think.

Wendy said if the organizationName is a national entity say a government agency where a specific locality  or state or Province would just be misleading are one of State/Province and Locality still required?

And you said  "In HARICA, most of our "clients" are members of the Academic and Research Community. I suppose that there is no way to establish a business in the entire country that would use the same DBA name of a University. There can only be one such name in the entire country. Adding Locality or State for such entities doesn't provide any additional security."

      Besides Wen-Cheng’s proposal, what about Ben’s new proposal after last week WG meeting? What about your thought?

  Ben proposes adding the following sentence(s) to sections on localityName and stateOrProvinceName:

This field is also optional if the organization is uniquely identifiable by registration in a national-government-adopted X.500 directory that does not contain the [localityName/stateOrProvinceName] attribute.

         Or you can see attached red-line version. Thank you.

                Li-Chun

From: Dimitris Zacharopoulos [mailto:jimmy at it.auth.gr] 
Sent: Tuesday, March 28, 2017 2:31 PM

Hi Li-Chun, 

On 27/3/2017 4:27 μμ, 陳立群 wrote:

Dimitris,

       In Taiwan, according our Company Act, the company name must be unique for the whole country

http://law.moj.gov.tw/Eng/LawClass/LawAll.aspx?PCode=J0080001

Please see  Company Act article 18, such as “No company may use a corporate name which is identical with that of another company. “

There will be no two companies with the same name such as  “ABC company” in Taiwan.       

     But what about in other country? Is it allowed two company with same company name in Greece?

If we are talking about "Subject Identity", as in most countries, it depends. At this point, we need to distinguish the "Company" with the "Subject" entity. BRs 3.2.2.1 describe validation of the identify of an "Organization". You realize that a "Company" is just one form of an "Organization". That said, and as you have clearly stated in your previous e-mails, some Organizations MUST be registered at the country level (for example Universities, Central Government Agencies/Units, maybe Medical Institutions) and cannot be registered at any other level (State, County, City or other). If you remember, I brought up this issue along with Wendy Brown from the FPKI because some Government Agencies and Public organizations are registered at a National Level so the Locality or State seems unnecessary. Depending on the size of the country, this rule could be expanded to Companies, as it appears to exist in Taiwan (unfortunately I did not have time to verify this but others may have done that already for Taiwan).

We should clearly distinguish the "streetAddress" with the "Subject Information". The mailing address must be any physical address related to the Organization identified in the "Subject Information" field as verified under 3.2.2.1. Since there is a clear attribute for physical address, why should we mix this information into the State or Locality Information?

The current BRs don't mandate that the Subject Information must uniquely Identify the Subject at a global or even a national scale. Normally, this information would be included in 3.1.5 (Uniqueness of names) and in several CP/CPS documents from various CAs you will see that the uniqueness of the Subject DN is usually at the Issuing CA level. Now, I've heard from CA/B Forum members that the "rationale/intent" of the "State OR Locality" rule was in order to have some information that uniquely identifies the Subject at a certain level (State or City). From the 14-month discussion of this topic, it is clear -at least to me- that this rationale/intent has failed... It would make more sense to force inclusion of the streetAddress field in OV Certificates rather than the "State or Locality".

I would not support Wen-Cheng’s proposal because it is overly specific to X.500 directory. I think this exception should be broader and allow for Organizations registered at a "National-Government" level (which means unique at a National level and no other Organizations can use the same Name at lower-levels) to be exempt from State and Locality field.

Best Regards,
Dimitris.

      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?

    So a better way is to let DN of the  corporation that registered at country-level be C=TW, O=Farmer’s Association

     And let DN of the  corporation that registered at city/county-level be

C=TW, L=Taipei City, O=Farmer’s Association

    Please see 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 for a corporation registered at country-level.  

      We hope you can support Wen-Cheng’s  https://cabforum.org/pipermail/public/2017-March/010123.html

to add a sub-section k under the section 7.1.4.2.2 Subject Distinguished Nam Fields as follows:

7.1.4.2.2 Subject Distinguished Nam Fields

……

k. Accepting X.500 Directory Naming Conventions of Existing PKIs

For PKIs where the X.500 directory naming conventions are adopted for subject distinguished names, the existing naming rules of those PKIs are acceptable if the following conditions are satisfied:

i. the naming rules can unambiguously identify the subject; and

ii. only commonly-used naming attributes recommended by RFC 5280, RFC 3739, or ETSI EN 319 412 are used in the naming rules.

   or support Ben’s version as https://cabforum.org/pipermail/public/2017-March/010215.html  that

adding the following sentence(s) to sections on localityName and stateOrProvinceName of SSL BR:

This field is also optional if the organization is uniquely identifiable by registration in a national-government-adopted X.500 directory that does not contain the [localityName/stateOrProvinceName] attribute.

    Please discuss. Thanks.

       Li-Chun Chen

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Dimitris Zacharopoulos via Public
Sent: Wednesday, March 22, 2017 10:21 PM
To: public at cabforum.org
Cc: Dimitris Zacharopoulos
Subject: [外部郵件] Re: [cabfpub] Naming rules

If both companies "ABC" are located in the same city, then with current rules, there will be a DN collision, right? I don't think you can avoid that with the current BRs.

Dimitris.

On 22/3/2017 3:56 μμ, Jeremy Rowley via Public wrote:

Correct. For #5 to be true, #3 must be true (which is still unclear), and OV must represent jurisdiction of incorporation (which it doesn’t). 

From: Ryan Sleevi [mailto:sleevi at google.com] 
Sent: Wednesday, March 22, 2017 7:33 AM
To: CA/Browser Forum Public Discussion List  <mailto:public at cabforum.org> <public at cabforum.org>
Cc: Gervase Markham  <mailto:gerv at mozilla.org> <gerv at mozilla.org>; Jeremy Rowley  <mailto:jeremy.rowley at digicert.com> <jeremy.rowley at digicert.com>
Subject: Re: [cabfpub] Naming rules

On Wed, Mar 22, 2017 at 9:30 AM, Jeremy Rowley via Public <public at cabforum.org> wrote:

There's one important item that seems unclear to me. What I took from reading Li Chun's message:

1)      Taiwan has a country-level registration
2)      Taiwan has a city-level registration
3)      The two are not mutually exclusive (ie ABC Company at the country level might be a completely different entity than ABC Company at the city level)
4)      You want the BRs to distinguish whether the ABC Company was registered with the country of Taiwan vs. a city registration.
5)      If locality is included in a cert, the actions of ABC Company (country) could be falsely attributed to the ABC Company (local)

I can't tell if #3 is true. If it is, then I can see why we'd want to make the change. If #3 is not true, then the change is only for convenience in Taiwan.

#5 is true if and only if we view OV information to indicate jurisdiction of incorporation. If it indicates physical address, then #5 is not true, correct? 

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