[cabfpub] a softer, gentler approach

Virginia Fournier vfournier at apple.com
Thu Apr 13 19:53:18 MST 2017


Reading all these email jabs is really tiresome.

Below is how I would have phrased this email.  I think it gets the same point across, in a much more pleasant and less adversarial way.  Thanks for listening.

==========================

Dear Kirk,

I’m sorry that I’m not doing a good job of communicating my point to you.  How about if we get on a call with Peter and Jeremy and try to figure this out.  Even though we have different perspectives, we’re all smart people and I’m sure we can come up with a resolution to this question.

I understand that it’s easy to misconstrue emails, and that we seem to be talking past each other.  I think it’s important that we are all satisfied with the resolution, and talking live will help us accomplish that.  I’m not sure I’m understanding the reference to legislative history, so maybe you could explain that as well.

Thanks very much for your assistance.

Virginia  

===========================

Best regards,

Virginia Fournier
Senior Standards Counsel
 Apple Inc.
☏ 669-227-9595
✉︎ vmf at apple.com






On Apr 13, 2017, at 7:35 PM, public-request at cabforum.org wrote:

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Today's Topics:

  1. Re: [EXTERNAL]Re:  Ballot 190: Domain Validation (Ryan Sleevi)
  2. Re: [EXTERNAL]Re: Ballot 190: Domain Validation (Ryan Sleevi)
  3. ??:  Ballot 194 - Effective Date of Ballot 193 Provisions is
     in the VOTING period (ends April 16) (xiongyuanyuan)


----------------------------------------------------------------------

Message: 1
Date: Thu, 13 Apr 2017 20:49:21 -0400
From: Ryan Sleevi <sleevi at google.com>
To: Kirk Hall <Kirk.Hall at entrustdatacard.com>
Cc: "CA/Browser Forum Public Discussion List" <public at cabforum.org>
Subject: Re: [cabfpub] [EXTERNAL]Re:  Ballot 190: Domain Validation
Message-ID:
	<CACvaWvbV_vGeSp1OwwrSaU2DRZjef09prPKRHzirH1c6p6MVZg at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"

On Thu, Apr 13, 2017 at 7:53 PM, Kirk Hall <Kirk.Hall at entrustdatacard.com>
wrote:

> Ryan, you weaken your case when you are patronizing to people.  If you
> don?t want to respond to my question (why not include legislative Notes on
> transition rules to the BRs right where they apply, as is commonly done),
> that?s your right, but again you weaken your case.
> 

Kirk,

If this was the ballot you were proposing, and I agreed with your goals, I
absolutely agree it would be useful to help you find the appropriate
language. Unfortunately, this is neither. Importantly for the discussion on
the list, it's not necessary to help you understand the issues, if other
people - such as Peter - clearly do. Importantly, if Jeremy understands
these issues, then it's sufficient. If you disagree with those changes,
which you have yet to address, and if your support for such changes was
necessary to adopt the ballot, then I agree, it'd be worthwhile to attempt
to explain to you again the nature of these issues.

I have tried a considerable number of ways to explain to you. It's clear
that, whether intentional or not, my explanations will not help you. Peter
clearly understands the set of concerns and issues, and so it's reasonable
to conclude at least some people find understanding on this issue, even if
you may not. That's sufficient to make progress, even if it may leave you
confused or unsatisfied. Given that your suggestions have, so far, been
unproductive, it doesn't seem worthwhile for you and I to continue
discussing this matter, other than to highlight to you, in your role as
Chair, the reminder that these are not legislative texts, but technical
specifications, and the need and importance of both precession and
capturing in the text.


> Yes, that will resolve ONE set of transition rules from ONE ballot ? but
> what do we do when we have another ballot that amends the same section?
> And then another?  (Gerv gave a good example of this possibility this
> morning relating to the .well-known validation rule as you recall).  Do we
> keep adding transition rules and effective dates over and over again to the
> same section?  That makes no sense, and is not generally how rule sets are
> amended and codified.
> 

I'm sorry this does not make sense to you. It's especially unfortunate,
because as I pointed out, this is exactly what the Forum has done and
continued to do.

As I mentioned to you on the call, we remain opposed to the very concept of
reusing the validation status - rather than the validation data. This is in
the effort of security.
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Message: 2
Date: Thu, 13 Apr 2017 20:52:42 -0400
From: Ryan Sleevi <sleevi at google.com>
To: "CA/Browser Forum Public Discussion List" <public at cabforum.org>
Subject: Re: [cabfpub] [EXTERNAL]Re: Ballot 190: Domain Validation
Message-ID:
	<CACvaWvYoen3DOFmN=Do42cV1QkHJYfwWz+pmpDs9N0qJOWb+rA at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"

On Thu, Apr 13, 2017 at 7:58 PM, Kirk Hall via Public <public at cabforum.org>
wrote:

> The CA does not have to revet Subscribers again until the prior data
> expires according to the normal rules for re-use of data.
> 

Kirk,

This is a misreading of the BRs. You do need to reverify the information,
using the existing data. This has been stated multiple times. If you're
doing something else, please stop, immediately.


> 
> 
> As Gerv said on the call today, it will be a disincentive for CAs ever to
> vote for incremental change in validation methods if the changes always
> take effect immediately, and wipe out the CA?s ability to re-use data that
> was properly collected according to the prior rules and is still in the
> permitted re-use period.  I don?t think anyone intended that result when we
> came up with Ballot 169 and now Ballot 190.
> 

Yes. We did. Because the existing methods are insecure, have lead to known
issues, and for which absolutely should not be relied upon for another
three years before CAs take meaningful steps to address their insecure
practices.

I can understand that you may wish to continue insecure practices. The goal
was to clarify that CAs should have better security, and should do so
promptly, considering we spent two years discussing changes after a year of
reporting the security issue before CAs took that matter seriously. We
proposed a phase in to allow CAs to adopt that (March 1, 2017). At that
time, any information obtained using the old methods that is not
used/acceptable under the new methods MUST be reissued.

The goal was to improve security. Section 2 actively undoes those years of
progress.
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Message: 3
Date: Fri, 14 Apr 2017 10:34:58 +0800
From: "xiongyuanyuan" <xiongyuanyuan at sheca.com>
To: "'CA/Browser Forum Public Discussion List'" <public at cabforum.org>
Subject: [cabfpub] ??:  Ballot 194 - Effective Date of Ballot 193
	Provisions is in the VOTING period (ends April 16)
Message-ID: <03c501d2b4c7$b6fdbea0$24f93be0$@sheca.com>
Content-Type: text/plain; charset="gb2312"

SHECA votes ABSTAIN on ballot 194.



Ruby Xiong

Shanghai Electronic Certification Authority co., ltd. 

18F, No.1717, North Sichuan Road, Shanghai, China

Tel?+86-21-36393197

Email? <mailto:xiongyuanyuan at sheca.com> xiongyuanyuan at sheca.com 

		
		
			





???: Public [mailto:public-bounces at cabforum.org] ?? Kirk Hall via
Public
????: Monday, April 10, 2017 7:30 AM
???: CA/Browser Forum Public Discussion List
??: Kirk Hall
??: [cabfpub] Ballot 194 - Effective Date of Ballot 193 Provisions is in
the VOTING period (ends April 16)



Reminder: Ballot 194 -  Effective Date of Ballot 193 Provisions is in the
voting period (ends April 16)



Ballot 194 ? Effective Date of Ballot 193 Provisions



Purpose of Ballot: Recent Ballot 193 reduced the maximum period for
certificates and for reuse of vetting data for DV and OV certificates from
39 months to 825 days.  The effective date for reducing the maximum validity
period of certificates was specified as March 1, 2018, but no effective date
was specified for when the reduction of the maximum period for reuse of
vetting data becomes effective.



It was the intention of the authors of Ballot 193 that the effective date
for reducing the maximum period for reuse of vetting data under BR 4.2.1
would also be March 1, 2018.  This ballot is intended to clarify that
intention.  The ballot also makes these changes retroactive to the effective
date of Ballot 193 so there is no gap period.



Ballot 193 is in the Review Period (which will end on April 22, 2017), and
has not yet taken effect.  Bylaw 2.3 states that Ballots should include a
?redline or comparison showing the set of changes from the Final Guideline
section(s) intended to become a Final Maintenance Guideline? and that
?[s]uch redline or comparison shall be made against the Final Guideline
section(s) as they exist at the time a ballot is proposed?.



To avoid confusion, this Ballot will show the proposed changes to BR 4.2.1
will be presented two ways: (1) a comparison of the changes to BR 4.2.1 as
it existed before Ballot 193 (which is as BR 4.2.1 exists at this time this
ballot is proposed), and also (2) a comparison of the changes to BR 4.2.1 as
it will exist after the Review Period for Ballot 193 is completed (assuming
no Exclusion Notices are filed).



The following motion has been proposed by Chris Bailey of Entrust Datacard
and endorsed by Ben Wilson of DigiCert, and Wayne Thayer of GoDaddy to
introduce new Final Maintenance Guidelines for the "Baseline Requirements
Certificate Policy for the Issuance and Management of Publicly-Trusted
Certificates" (Baseline Requirements) and the "Guidelines for the Issuance
and Management of Extended Validation Certificates" (EV Guidelines).



-- MOTION BEGINS -- 



Ballot Section 1



BR 4.2.1 is amended to read as follows:



[Ballot amendments shown against BR 4.2.1 as it currently exists without the
changes adopted in Ballot 193]



BR 4.2.1. Performing Identification and Authentication Functions



The certificate request MAY include all factual information about the
Applicant to be included in the Certificate, and such additional information
as is necessary for the CA to obtain from the Applicant in order to comply
with these Requirements and the CA?s Certificate Policy and/or
Certification Practice Statement. In cases where the certificate request
does not contain all the necessary information about the Applicant, the CA
SHALL obtain the remaining information from the Applicant or, having
obtained it from a reliable, independent, third?party data source, confirm
it with the Applicant. The CA SHALL establish and follow a documented
procedure for verifying all data requested for inclusion in the Certificate
by the Applicant.



Applicant information MUST include, but not be limited to, at least one
Fully?Qualified Domain Name or IP address to be included in the
Certificate?s SubjectAltName extension.



Section 6.3.2 limits the validity period of Subscriber Certificates. 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.



(1) Prior to March 1, 2018, the CA obtained the data or document from a
source specified under Section 3.2 no more than 39 months prior to issuing
the Certificate; and



(2) On or after March 1, 2018, the CA obtained the data or document from a
source specified under Section 3.2 no more than 825 days prior to issuing
the Certificate. 



The CA SHALL develop, maintain, and implement documented procedures that
identify and require additional verification activity for High Risk
Certificate Requests prior to the Certificate?s approval, as reasonably
necessary to ensure that such requests are properly verified under these
Requirements.



If a Delegated Third Party fulfills any of the CA?s obligations under this
section, the CA SHALL verify that the process used by the Delegated Third
Party to identify and further verify High Risk Certificate Requests provides
at least the same level of assurance as the CA?s own processes.





[Ballot amendments shown against BR 4.2.1 as it existed after Ballot 193 was
approved]



BR 4.2.1. Performing Identification and Authentication Functions



The certificate request MAY include all factual information about the
Applicant to be included in the Certificate, and such additional information
as is necessary for the CA to obtain from the Applicant in order to comply
with these Requirements and the CA?s Certificate Policy and/or
Certification Practice Statement. In cases where the certificate request
does not contain all the necessary information about the Applicant, the CA
SHALL obtain the remaining information from the Applicant or, having
obtained it from a reliable, independent, third?party data source, confirm
it with the Applicant. The CA SHALL establish and follow a documented
procedure for verifying all data requested for inclusion in the Certificate
by the Applicant.



Applicant information MUST include, but not be limited to, at least one
Fully?Qualified Domain Name or IP address to be included in the
Certificate?s SubjectAltName extension.



Section 6.3.2 limits the validity period of Subscriber Certificates. 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 825 days prior to issuing
the Certificate.



(1) Prior to March 1, 2018, the CA obtained the data or document from a
source specified under Section 3.2 no more than 39 months prior to issuing
the Certificate; and



(2) On or after March 1, 2018, the CA obtained the data or document from a
source specified under Section 3.2 no more than 825 days prior to issuing
the Certificate. 



The CA SHALL develop, maintain, and implement documented procedures that
identify and require additional verification activity for High Risk
Certificate Requests prior to the Certificate?s approval, as reasonably
necessary to ensure that such requests are properly verified under these
Requirements.



If a Delegated Third Party fulfills any of the CA?s obligations under this
section, the CA SHALL verify that the process used by the Delegated Third
Party to identify and further verify High Risk Certificate Requests provides
at least the same level of assurance as the CA?s own processes.



Ballot Section 2



The provisions of Ballot Section 1 will be effective retroactive to the
effective date of Ballot 193.





--Motion Ends--



The procedure for approval of this Final Maintenance Guideline ballot is as
follows (exact start and end times may be adjusted to comply with applicable
Bylaws and IPR Agreement):




BALLOT 194

Status: Final Maintenance Guideline

Start time (22:00 UTC)

End time (22:00 UTC)


Discussion (7 to 14 days)

April 2, 2017

April 9, 2017


Vote for approval (7 days)

April 9, 2017

April 16, 2017


If vote approves ballot: Review Period (Chair to send Review Notice) (30
days).  

If Exclusion Notice(s) filed, ballot approval is rescinded and PAG to be
created.

If no Exclusion Notices filed, ballot becomes effective at end of Review
Period.

Upon filing of Review Notice by Chair

30 days after filing of Review Notice by Chair



> From Bylaw 2.3: If the Draft Guideline Ballot is proposing a Final
Maintenance Guideline, such ballot will include a redline or comparison
showing the set of changes from the Final Guideline section(s) intended to
become a Final Maintenance Guideline, and need not include a copy of the
full set of guidelines.  Such redline or comparison shall be made against
the Final Guideline section(s) as they exist at the time a ballot is
proposed, and need not take into consideration other ballots that may be
proposed subsequently, except as provided in Bylaw Section 2.3(j).



Votes must be cast by posting an on-list reply to this thread on the Public
list.  A vote in favor of the motion must indicate a clear 'yes' in the
response. A vote against must indicate a clear 'no' in the response. A vote
to abstain must indicate a clear 'abstain' in the response. Unclear
responses will not be counted. The latest vote received from any
representative of a voting member before the close of the voting period will
be counted. Voting members are listed here:  <https://cabforum.org/members/>
https://cabforum.org/members/ 



In order for the motion to be adopted, two thirds or more of the votes cast
by members in the CA category and greater than 50% of the votes cast by
members in the browser category must be in favor.  Quorum is shown on
CA/Browser Forum wiki.  Under Bylaw 2.2(g), at least the required quorum
number must participate in the ballot for the ballot to be valid, either by
voting in favor, voting against, or abstaining.



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