[cabfpub] Preballot - Revised Ballot 190

[Peter Bowen]

> On May 19, 2017, at 5:13 PM, Ryan Sleevi <sleevi at google.com> wrote:
> 
> 
> 
> On Fri, May 19, 2017 at 7:52 PM, Peter Bowen <pzb at amzn.com <mailto:pzb at amzn.com>> wrote:
> 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.
> 
> And this goes back to the initial question you posed that kicked this all off, namely:
> "I think some have suggested that the BRs don’t allow this alternative order of operations, but I’m having a little trouble finding the specific cite.  Do you, Ryan, or does anyone else, think the order of operations described above is not valid?"
> 
> To tie this all back together: Section 4.2.1 only permits the reuse of information gathered in context with Section 3.2:
> "The	CA	MAY	use	the	documents	and	data	
> provided	in	Section	3.2	to	verify	certificate	information,	provided	that	the	CA	obtained	the	data	or	document	
> from	a	source	specified	under	Section	3.2	no	more	than	thirty‐nine	(39)	months	prior	to	issuing	the	
> Certificate."
> 
> Section 3.2 is tied to what the Applicant is requesting in the certificate:
> 
> So for there to be information to be reused, it needs to be obtained in the context of an Applicant. 
> 
> And so the question is whether or not there can be an Applicant prior to a Certificate Request.
> 
> Section 1.6.1 establishes the Applicant as: "The	natural	person	or	Legal	Entity	that	applies	for	(or	seeks	renewal	of)	a	Certificate. Once	the	
> Certificate	issues,	the	Applicant	is	referred	to	as	the	Subscriber.		For	Certificates	issued	to	devices,	the	
> Applicant	is	the	entity	that	controls	or	operates	the	device	named	in	the	Certificate,	even	if	the	device	is	
> sending	the	actual	certificate	request.	"
> 
> I'm sure we can get into the game of debating whether 'applies for' is distinct from 'requests' (although I think that's not supported by the text itself, by virtue of the following sentence, but I'm sure we can misread it).
> 
> 
> You asked if there was a reason to suggest the ordering must be different. My minimal suggestion was that the order must be:
> 
> - A Request, which includes the attestation of correctness (per 4.1.2)
> - which establishes an Applicant (per 1.6.1)
> - which then permits validation of the Applicant information (per 3.2)
> - which can then be reused for subsequent Requests (per 4.2.1)
> 
> It would seem that you are advocating for an interpretation that establishes:
> - An Applicant (by virtue of establishing an Applicant Representative - the party who has signed the Subscriber Agreement on behalf of the Applicant / acknowledges the TOU, per 1.6.1)
> - which then permits validation of the Applicant information (per 3.2)
> - Which then permits one or more Requests (per 4.1.2)
> - Which then allows the validated information to be reused (per 4.2.1), or the reuse of a previously completed validation (per 3.2.2.4)
> 
> Is that a correct summary of the difference?

There is another way to look at it.  Applicant is a defined term that is basically a pronoun.  It is reasonable to replace the capitalized “Applicant” with a specific natural person or legal entity.  So the 3.2 validations can be performed against a specific legal entity — e.g. Aperture Science, Inc.  Given that completed validations can be reused, it stands that one could validate that Aperture Science, Inc. controls example.com <http://example.com/>, then use that later to issue a certificate.  I think you are getting hung up on a concept that the only way to resolve “Applicant” to a specific entity is via the Applicant submitting a certificate request.  I don’t see anything that forbids a CA from validating that a natural person or legal entity controls a domain or exists outside of a request then reusing that to satisfy a future future validation request.

Thanks,
Peter
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