Frank, in order to continue the discussion below I really want to 
understand first

1.) If our stated goal is simply to facilitate the inclusion of as many 
CAs as possible
2.) If the principals guiding us are limited to the Mozilla CA policy only
3.) And if is, what we want, simply to provide just a process for 
inclusion of CAs

If it's #1 then perhaps I'd better not comment anymore because I might 
be obstructing the goal
If it's #2 but not #1, I'd like to know if and how we can modify and 
update the Mozilla CA policy so that it's up to the task for the current 
inclusion requests (including this one).
If it's #3 or all of the above, lets not bother seriously with the 
policy and process anymore, since the process is currently flawed to a 
certain extend and the policy not up to the task it was assigned to.

If however our goal is to provide and warrant a certain level, standard 
and quality of certificates issued by the CAs included in NSS on which 
the users of Mozilla software can rely on and on the principal that CAs 
have to conform to certain guidelines (and "spirit"), rules and 
principals on equal footing and if we want to provide a reasonable level 
of security and reliance, than I'm glad to provide my expertise and 
experience on the subject.

For the meantime some answers below...

Frank Hecker:
>
> Maybe I'm missing something, but I don't think this situation is unique 
> to KISA.

This situation is unique in that, that KISA is a boot strapping CA only. 
There were and are other such CAs (which requested inclusion), most of 
them are commissioned by their respective governments to oversee the 
rules and laws of that country. These are their laws and each country 
handles it differently. _KISA is not a CA which is covered under the 
Mozilla CA policy_ and we'll have to define the term CA and what we 
understand with this term when discussing here.


> I believe there are commercial CAs, including CAs already in 
> our root list, that issue CA certs to independently operated CAs.

Of which this is only part of their CA business. In that respect I'd 
suggest that such CAs must have a policy and or clearly fall under the 
policies of the parent CA and be audited as part of the CA 
infrastructure and have a stipulation in that respect in the parent CA 
policy.

>  If I 
> recall correctly, this is what our IT department did when I worked at 
> Netscape, namely run a Netscape enterprise CA using an 
> internally-operated CA infrastructure, with a CA cert issued to Netscape 
> by an external commercial CA.
>   

Not arguing with that, however Netscape was most likely in a unique 
position. But one "wrong" doesn't makes it a "right". You are speaking 
here about something which happened some ten years ago. Not that I see a 
problem with it per se, but it depends how this is handled by the parent 
CA and which conditions and definitions we attach in that respect to the 
Mozilla CA policy. Auditing of the full CA infrastructure, including 
external CAs is a requirement in order guaranty the integrity of our set 
of CAs in NSS. Otherwise this would effectively circumvent one of the 
basic requirements of the Mozilla policy (See my suggestions from above).

> So I don't think this is a question of government CAs vs. non-government 
> CAs, or even "standard CAs" vs. "bootstrapping CAs", it's part of the 
> more general question of how to handle subordinate CAs.

No, I don't agree. If the intermediate CAs are used within the CA 
infrastructure to which the policies and audits apply, then we don't 
need any additional stipulation for that (in the Mozilla CA policy). I 
call this a standard CA such as StartCom is.

If the sole purpose of a CA is to bootstrap other CAs (for whatever 
reasons, being it for commercial reasons or being it to govern a certain 
law), then the sub ordinated CAs are really CAs and we need a definition 
and agreed rules about how we want to handle it.

>  As I said, I 
> think there are CAs operating today, including commercial CAs, that in 
> some contexts act like "standard CAs" issuing end-entity certs out of 
> their own infrastructure, and in other contexts act as "bootstrapping 
> CAs" enabling other organizations to operate their own CAs. I don't 
> believe that the distinction is as clear-cut as you suggest it is.
>   

Correct and that's why we need to hold on for a moment and think about 
what we really want, what is sane and what we want to achieve with what 
we are doing here. At many organizations (including military, 
governments, companies and CAs) operations are stopped when a flaw is 
detected until a decision has been made about how to solve that flaw. 
You suggest however to pretend the flaw doesn't exist and continue as 
usual. Would you have been a air-force commander you would be putting 
your pilots at risk (just to give an example how this looks elsewhere :-) )

>
> I evaluate requests according to the policy we have, not the policy you 
> (or anyone else, including me for that matter) wish we had. 

If the policy doesn't provide you with enough answers and definitions in 
order to make a clear decision, than it's perhaps your fault that you 
continue the process without fixing the policy.


> As I've written before, if the policy doesn't address certain issues that 
> arise 
> in the context of individual CA requests,

Then you should be guided by the stated goals and principals (which are 
not clear to me right now) and start to address the issues because they 
might come up again.

> I am not going to hold up such 
> requests until we hash through all the details of changing the policy, 
> nor am I going to impose on the CAs making such requests new 
> requirements that go beyond the policy as it's written and as it's been 
> applied in the past.
>   

Supposed a CA does something about which the policy doesn't provide 
answers, but which would effectively compromise the level of quality and 
security requirements of the CAs in NSS, than you would be acting 
irresponsible. For example auditing of CAs is a requirement by the 
policy, but as in this case, this requirement is effectively 
circumvented. Why should I agree to it? Lets get rid of this requirement 
and let the CAs save a few bucks then....either we require it or we 
don't. I'm completely against auditing by proxy and auditing where only 
the root CA is covered, but the real CA business is really elsewhere.


-- 
Regards 
 
Signer:         Eddy Nigg, StartCom Ltd. <http://www.startcom.org>
Jabber:         [EMAIL PROTECTED] <xmpp:[EMAIL PROTECTED]>
Blog:   Join the Revolution! <http://blog.startcom.org>
Phone:          +1.213.341.0390
 

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