"Having said that, neither myself nor the company I run have gained
financially from this - currently it seems that all CAs have taken
damage. Reckless behavior is ruining our businesses, the trust we try
to
build and the strengthening of Internet security at large is put into
jeopardy. It is my duty to prevent that if possible.


There is no conflict of interest even if the result of my involvement
would put a competitor out of business - it's their failure not mine.
And with it, they risk the reputation and security of Mozilla and all
relying parties which depend on it. "

Riiiight.

Couple of observations on all of this (having read most all of the
other original thread) as a disinterested observor (Full disclosure: I
used to resell SSL certs some time back).

1. You kid only your self if you think you have no appearance of
conflict of interest in this issue. You do, in spite of your wishing
not to. But you are not alone. The prior thread was in full dogpile
mode against Comodo by a few who seem to have some baggage against
them by the levels of reaction compared to the severity of the issue
and its corresponding triage by Comodo. IMHO

2. You would do well to reflect and consider whether or not the
complete commodization of domain validated certificates themselves,
both by their very nature (email validation of domain ownership. I
mean really now), as well as the pricing models employed by the
various competitors in the SSL field (yourself notable among them)
have not done more harm to the industry, or more specifically the
relative level of security, authority and credibility of SSL as a
security model, as perceived by users. Once one acknowledges that
being a CA is nothing more than a license to print money, subject to
independent operational audits, then you can have a meaningful
discussion on what 'security' your providing to a user. See EV
validation procedures and their corresponding pricing model, compared
to Organization Validated certs if you care to refute that statement.
Yes, I'm looking at you Verisign.

There is such a low barrier to entry for a Domain Validated
certificate even when the system works correctly. A couple of bucks to
register a domain name with GoDaddy, a couple more (or zero) dollars
to get an SSL cert, and any script kiddy worth his salt can now start
blasting out "Please login to your BOA savings account to reverify
your account info", and hope for a MITM opportunity to pop up on his
monitor, DV certs have next to zero credibility on ANY website that
purports to protect personal or financial info. You know that I'm
sure. There are tons MITM attacks sucessfully carried out every year
by crooks who have VALID DV certs on their fraud sites. How do you
think RSA sells so many handheld password tokens? Which begs the
question of why Mozilla needs to suddenly go into fire drill mode over
RA auditing practices with respect to Comodo. Its a joke.

3. I was a little taken aback at the surprise and shock expressed by
the resident experts that Comodo RA resellers do DV authentication (or
at least, are supposed to as part of their resale agreements). Is this
to imply that NONE of the other CAs that have wholesale agreements
with third party resellers allow a DV cert to be sold pending CA
relegated authentication directly? Are we that naive in 2009? Thawt?
Globalsign? Verisign? RapidSSL? GoDaddy? Surely Comodo is not the only
one out there that allows their resellers to perform initial DV cert
validation subject to CA audits. I can't prove it, but I'd bet $20,
the number of primary CAs who do is greater than 1. Someone, it
appears, has never taken a look at the Certification Practice
Statements of the various CA's I guess (to the extent that you can
find them all). I seem to recall that the RSA X.509 spec allows for
this type of subservient RA model as long as proper audit controls are
in place to maintain verification compliance.

In a nutshell, does anyone who declares himself an expert in the SSL
industry REALLY think this cause irreprerable harm to the other CAs?
Should Comodo tighten up on its audit procedures? Certainly looks that
way. But since any primary CA out there who does this probably only
does sample audits (are YOU going to pay KPMG their hourly to go
through every record out in the field? Not bloody likely), the
possibility still exists for that 'rogue' cert to skate by. If total
security is paramount, should not all CAs make sure third party
resellers validate all domains internally through them? Absolutely,
but be careful about the unintended consequences of what that would do
the internal costs to the CAs, and the subsequent knock on costs to
the channel. It might even raise the prices in the street a little if
they all did it at once, somehting positive! However if the X.509 spec
doesn't call for it, whos first in line to volunteer to implement it
for DV certs? Thats what you have OV and EV certs for, no? And
afterall, as all know, money is ultimately the reason in the SSL
community for the model you have. Security is like the old analogy
about getting race cars to go faster, theres always a way to improve
it, but its only limited by how much money you want to spend on it.

(fireproof suit - ON)

Mark
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