Merely commenting on matters of fact:

Kaspar Brand wrote:
> That doesn't imply everything was perfect with this application at that
> time. Have you ever seen a root certificate with a nonRepudiation
> keyUsage extension? Yes, Startcom's current one does have that... Or,
> what RSA key size would you use for a 30-year root issued in 2005?
> Startcom thinks 1024 is enough...

The purpose of this application is not to re-evaluate a previous 
application or the suitability of a previous certificate, but to 
evaluate the current one.

> This CA was last "audited" at the end of 2005 (more than one and a half
> year ago), by a third party whose qualification is certainly debatable -
> and based on last year's decision, the application should now just be
> routinely approved?

There is nothing in the CA Certificate Policy which requires a 
particular audit frequency. There has been a suggestion that this is 
changed, and this suggestion will be discussed during the next round of 
policy updates.
https://bugzilla.mozilla.org/show_bug.cgi?id=381850

> So, leaving aside the lack of auditing expertise of the consulting
> company in question, do you really think they were a "competent party"
> when they looked at Startcom (and its home grown root cert) in 2005?

Again, it is not within the scope of this application to re-evaluate 
this decision, unless further information comes to light on the 
independence and/or competence of the auditors.

Gerv
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