[cabfpub] Preballot - Revised Ballot 190

Peter Bowen pzb at amzn.com
Fri May 19 23:52:46 UTC 2017

> On May 19, 2017, at 3:07 PM, Ryan Sleevi <sleevi at google.com> wrote:
> On Fri, May 19, 2017 at 6:00 PM, Peter Bowen <pzb at amzn.com <mailto:pzb at amzn.com>> wrote:
> Yes, it does.  We know that CAs can generate keys on behalf of the subscriber, so it is clear that a public key is not required.  This means that a CA could take the request for “issue a certificate to example.com <http://example.com/>”, do validation and key generation, throw away the private key, issue the cert, and end up with a “pre-validated” domain.  This is compliant.  The generated cert could have some flag in it, similar to a pre-cert, that makes it unusable for any real world purpose, and it would still be fine.  But this is silly.  We don’t want to have hoop jumping for no discernible value.
> Can you suggest a change that you feel would make it clear that CAs may validate identities (organizations, domains, etc) independent of issuing certificates and use the documents and data gathered during such validation for future issuance, subject to the aging requirement of 4.2.1?  I would suggest a change myself, but I’m not quite clear which part of the BRs you feel prevents this today.
> The BRs are gated on the concept of an Applicant - all of the validation is done in concert and connection with an Applicant.
> I'm not sure how it makes sense for CAs to have, say, a prevalidated set of organizations, any of which can apply and thus reuse the information.

It makes sense if an organization comes to the CA, signs a contract that includes the subscriber agreement, then requests validation of domain and organization identities (because affiliates can be validated, it is possible there are multiple organization identities bound to a single applicant organization).  Then same organization comes back and request a certificate in the future.  There is no confusion about the Applicant.

> Put differently: Do you think it would be BR conformant if a CA looked through CT, determined which organizations had OV/EV certs, worked through QIIS/QGIS's to 'prevalidate' the organizational information related to it, and then approached all customers with the remark "We can give you a certificate in 30 seconds?"
> It may be that the answer is yes - that the extent of the CAs obligations (to validate the documents and domain, in absentia of an Applicant) are met.
> It may be that the answer is no - that a CA cannot begin doing some form of validation until contacted by an Applicant.

There is no reason a CA couldn’t pull public records based on info in CT to help expedite things (for example identifying the company registration number), but the validation still has to happen. You can’t finalize the validation without binding it to a legal entity who will be the applicant/subscriber.  It is possible that this validation could use records pulled by the CA prior to the request for validation.

> But I think understanding the specific answer to this scenario can help inform whether or not an "Applicant" is required to make a certificate request before being, well, an "Applicant".
> If they are required to make a request, then naturally, it follows that your so-called hoop-jumping is necessary, since there is a minimum definition of what constitutes a certificate request.
> If they are not required to make a request, then naturally, the scenario I described is the logical extreme, in which the CA can validate 'everything but the application'. To further add to the extreme, it might be possible for the CA to pre-generate the public key, and just call up the subscriber and say "Do you want a cert" - with that assent being sufficient to constitute an “Application"

I would think that a valid application could be made via a phone call, especially if there is an existing subscriber agreement in place and the CA is expected to generate the key.


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