Hi Eddy.  I'm not the right person to answer your questions about our CPS.  I 
have asked my colleague Robin Alden to join this newsgroup and answer each of 
your points.

On Sunday 16 March 2008, Eddy Nigg (StartCom Ltd.) wrote:
> This is a revised version of my initial questions concerning the Comodo
> inclusion and upgrade requests. I've updated the sections which received
> a response from Frank and are solved from my point of view and added
> some more content where deemed necessary.
>
> 1.) The audit report for non-EV operations refers to the CA operation at
> Manchester. The audit report for EV refers to the CA operations at New
> Jersey. One of the roots is from a company operating in Sweden, one
> operating in Salt Lake City, Utah, USA and and one of Salford, GB. Can
> the relations between these locations and the general operation of
> Comodo and the audit reports be explained?
>
> Additionally I would like to know to whom belongs the company LITESSL
> CA, INC. and its relationship to Comodo CA Ltd. as referenced in the
> audit report from KPMG
> (https://cert.webtrust.org/SealFile?seal=636&file=pdf). What are its
> relations to AddTrust AB, Sweden? In the audit reports no distinctions
> are made between the various companies and the audit reports are
> addressed only to Comodo CA Ltd.
>
> 2.) The Comodo Certification Practice Statement, Version 3.0 and other
> CPS amendments state that wild card certificates are domain name
> validated only (depending on product or trade mark). How does Comodo
> prevent or control misuse of wild card certificates, specially in
> relation to phishing attempts and other fraud, taking into consideration
> that these certificates are domain validated only? Does Comodo believe
> that such wild card certificates are issued according to verification
> requirements for this special type of certificates?
>
> 3.) The Comodo Certification Practice Statement, Version 3.0 and other
> CPS amendments state certificate validity of up to ten years and beyond.
> I couldn't find any provision in case the domain name expires. It isn't
> clear what happens if an identity or organization changes name, changes
> address, stops its operation, dies etc. How does Comodo guaranty the
> validity of these certificates throughout their lifetime?
>
> 4.) Frank, this one is for you:
>
> Since most (if not all) CA root certificates of Comodo were inherited
> from the Netscape era and never were properly evaluated by an inclusion
> process and in light of the questions above, isn't a thorough review of
> this CA in place in order to guaranty conformance to the Mozilla CA
> policy? Because an upgrade to EV would tie this CA further into NSS I
> believe that such a review should be performed prior to any other step.
> I haven't invested a lot of time into this request initially (as I
> haven't for other upgrade requests for EV during the comments period),
> but raised enough questions which might justify such a review.



-- 
Rob Stradling
Senior Research & Development Scientist
Comodo - Creating Trust Online
Office Tel: +44.(0)1274.730505
Fax Europe: +44.(0)1274.730909
www.comodo.com

Comodo CA Limited, Registered in England No. 04058690
Registered Office:
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