On Dec 23, 5:56 pm, ro...@comodo.com wrote:
> Comodo takes it responsibility to supervise RAs very seriously and we
> actively audit their performance. While it is not practical to audit
> 100% of their work, we audit a representative sample.

By delegating RA functions (including domain verification) to third
parties, you appear to be making them the weakest links in PKI chains
of trust.

> We apologize for Certstar’s mistake and assure you that we will
> redouble our self-auditing efforts to insure the problem does not
> repeat itself.

Some questions:

1. Does Comodo take full responsibility for the actions of its
resellers? If so, how should the repercussions of such failures be to
Comodo?

2. Are resellers subject to the same audits that Comodo presumably had
to undergo to get its root certs added to Mozilla? Who performs, and
who verifies such audits? How often are they performed?

3. Are you willing to openly, continually disclose your list of
resellers, the frequency of audits, audit methodology, and actual
audit reports so that third parties can evaluate whether Comodo is
trustworthy as a CA?
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