Wayne covered what I was going to say. I would also add that using the word
blackmail in this context would also probably be seen as a code of conduct
violation.

I do hope we can call out lines of questioning in the future without
resorting to such language.

Thanks!

On Sat, Oct 19, 2024 at 05:08 'Dimitris Zacharopoulos (HARICA)' via CCADB
Public <[email protected]> wrote:

> I'm sorry for jumping-in. Speaking in a personal capacity, I feel quite
> uncomfortable with this line of questioning, especially during inclusion
> request discussions where a CA is asking for approval after having
> fulfilled all the listed expectations of the Root Store policies. I believe
> it is not in line with the community's history and values and not in line
> with the CoC
> <https://docs.google.com/document/d/19ALqEvHtTE6OUTz2FaOXrU9gruIdvia5EDh3hXeGpZA/edit?tab=t.0#heading=h.cumc0pgd1s7c>
> of this list.
>
> On one hand we see questions related to political views (by association?)
> of a person previously associated with a CA (based on D-TRUST's recent
> post, it is clear that Kim is no longer managing D-TRUST), and on the other
> hand we see questions about willingness to support a certain opinion about
> 90-day certificates. Felt to me a bit like "blackmail".
>
> This should be a non-discriminatory forum where one's political views
> should not be judged or questioned. If we go down that path, what prevents
> people from asking if a person would vote in favor of some governmental
> policy or in favor of a certain politician, candidate president, ....? Does
> the candidate CA support Article X in candidate legislation Y? This should
> not be acceptable.
>
> Same with the 90-day certificates question. There are many that disagree
> with the 90-day certificates for various reasons, and there is opportunity
> for discussion in the CA/B Forum when a ballot is officially introduced.
> There is currently a lot of debate on
> https://github.com/cabforum/servercert/pull/553 and other discussion
> forums, which demonstrates that this is a very controversial topic. Does
> that mean that any CA that doesn't agree with the 90-day certificates
> should not be part of the WebPKI or Public Trust? IMHO it is not reasonable
> to request a candidate CA to commit to support (and not object to?) 90-day
> certificates as prerequisite for inclusion, when it is not even a Mozilla
> policy.
>
> I'm curious if the CCADB steering committee finds this line of questioning
> acceptable based on the CoC
> <https://docs.google.com/document/d/19ALqEvHtTE6OUTz2FaOXrU9gruIdvia5EDh3hXeGpZA/edit?tab=t.0#heading=h.cumc0pgd1s7c>
> .
>
> I hope I am not the only one who sees these issues as problematic.
>
>
> Thank you,
> Dimitris.
>
>
>
>
> On 18/10/2024 11:45 μ.μ., 'Amir Omidi' via CCADB Public wrote:
>
> Accidentally didn't press reply all.
>
> I don’t think this answer really answers the question posed by Mike. This
> person was still working there during their advocacy in this space.
>
> Given this advocacy of the director in the past, would D Trust willingly
> accept to issue maximum 90 day certificates?
>
> Thanks
>
>
> On Fri, Oct 18, 2024 at 15:36 'Entschew, Enrico' via CCADB Public <
> [email protected]> wrote:
>
>> Hi Mike,
>>
>> Thanks again for your comments.
>>
>>
>>
>> First of all, I would like to briefly inform you that Dr Kim Nguyen is no
>> longer Managing Director of D-Trust as of the beginning of this year. He is
>> currently Senior Vice President Innovations at Bundesdruckerei.
>>
>>
>>
>> D-Trust is a committed, loyal and active member of the web PKI community.
>> We follow the discussions on mdsp, github (CA/B-F specific), CCADB list,
>> Bugzilla etc. We attend the F2F CA/B Forum and WG meetings regularly. Twice
>> D-Trust hosted a F2F CA/B Forum meeting in Berlin. We comply with the
>> requirements of the CA/Browser Forum and the root store policies of the
>> browsers, which is checked annually by an independent Conformity Assessment
>> Body in a multi-day audit.
>>
>>
>>
>> If we make mistakes, we openly communicate them via the Bugzilla platform
>> of Mozilla. We analyze the errors, publish the root cause of the error,
>> propose measures to prevent future errors and implement the measures as
>> quickly as possible. If possible, we contribute changes to the tools that
>> the community uses, e.g. open source linter ZLint, to help prevent other
>> CAs from making the same mistakes as us. D-Trust has always strived to
>> react openly and transparently to incidents, as the Web PKI community has
>> expected us to.
>>
>>
>>
>> If you have questions about these topics I’m happy to answer them here.
>>
>>
>>
>> Thanks,
>>
>> Enrico
>>
>>
>>
>>
>>
>> *Von:* [email protected] <[email protected]> *Im Auftrag von *Mike Shaver
>> *Gesendet:* Dienstag, 15. Oktober 2024 03:38
>> *An:* Entschew, Enrico <[email protected]> <[email protected]>
>>
>> *Cc:* Ryan Dickson <[email protected]>; public <[email protected]>
>> *Betreff:* Re: Public Discussion of D-Trust TLS CA Inclusion Request
>>
>>
>>
>> Thanks for the reply, Enrico.
>>
>>
>>
>> Is it the case that roll-over “routine” inclusion requests should be
>> subject to less scrutiny than original applications for inclusion? I
>> couldn’t readily find anything in the CA/BF BRs or CCADB bylaws to that
>> effect. What are the sorts of things that are appropriate to bring up for
>> an application for continued inclusion, and what topics are only suitable
>> for consideration during initial inclusion? If it’s impossible for
>> behaviour (or concerns regarding behaviour arising) between initial
>> inclusion and roll-over to cause a root to be removed from CCADB’s list,
>> then I think it calls into question the whole purpose of the commentary
>> period and indeed re-inclusion process. If it *is* possible for
>> re-inclusion to be refused by the CCADB, then it’s just a matter of
>> determining what topics are appropriate for discussion during re-inclusion
>> evaluation. I welcome clarification on this topic from other CCADB members,
>> of course; ideally those clarifications would be rooted, if you will permit
>> a gentle pun, in established policy.
>>
>>
>>
>> To be clear, I don’t have any questions about the ESD’s position
>> papers—they are written in utterly clear ways—but rather about D-trust’s
>> positions and what D-Trust’s advocacy and endorsement might indicate about
>> their *own* positions with respect to the web PKI. I am asking an ESD
>> member to reply, I suppose, but on the basis of their own positions, and
>> not on behalf of ESD. It may well be that D-Trust no longer holds those
>> positions itself, for example, and therefore is not endorsing ignoring of
>> root programs based on market share, or maintaining against the reality of
>> the anti-trust agency’s report that reduction in certificate validity
>> period represents anti-competitive and anti-security practice. I would
>> certainly welcome that news! It may however be the case that D-Trust holds
>> those positions still, and that they will necessarily inform how it
>> operates as a CA, which I confess would be less welcome news personally,
>> but perhaps CCADB members would celebrate it? The only way to find out is
>> to have the questions answered. These are both “live questions”, with
>> Apple’s proposed reduction schedule and the role that the Mozilla root
>> community played in uncovering and forcing action on Entrust’s unacceptable
>> operations as a CA.
>>
>>
>>
>> If the ESD were members of CCADB’s root list themselves, though, I would
>> certainly have many concerns about them being re-included through shallow
>> “routine” evaluation, given their recent statements on topics relevant to
>> the web PKI. Happily, from my perspective, they are not such a member!
>>
>>
>>
>> Mike
>>
>>
>>
>> On Mon, Oct 14, 2024 at 9:05 PM Entschew, Enrico <[email protected]>
>> wrote:
>>
>> Hi Mike,
>>
>>
>>
>> Thanks for your questions.
>>
>> This CCADB thread is a routine root inclusion request from D-Trust.
>> Specifically, this is a request for including roll-over CAs for already
>> existing and already included root CAs for TLS and S/MIME.
>>
>> On this basis, your questions relating to ESD position papers and the
>> eIDAS legislative process are not really related to the root inclusion
>> request.  If you want to discuss the topics you raised, we suggest you
>> bring them up in a new thread on CCADB, and ESD and its members can respond
>> as appropriate.
>>
>>
>>
>> Thanks,
>>
>> Enrico
>> ------------------------------
>>
>> *Von:* [email protected] <[email protected]> im Auftrag von Mike Shaver <
>> [email protected]>
>> *Gesendet:* Donnerstag, Oktober 10, 2024 11:55 AM
>>
>>
>> *An:* Ryan Dickson <[email protected]>
>> *Cc:* public <[email protected]>
>> *Betreff:* Re: Public Discussion of D-Trust TLS CA Inclusion Request
>>
>>
>>
>> Hi,
>>
>>
>>
>> I was not really familiar with D-Trust, so I did some searching and
>> asking, and I have found something that I would like to raise for
>> consideration.
>>
>>
>>
>> D-Trust's director, Dr. Kim Nyugen, is an expert member of the European
>> Signature Dialog: https://www.european-signature-dialog.eu/Kim-Nguyen
>>
>> The ESD has very vocally and, in my opinion, misleadingly campaigned
>> against shorter certificate lengths, framing the 90-day proposal (initially
>> Google's, but I supported by other root programs and CAs since then) as
>> "anti-competitive behaviour":
>> https://www.european-signature-dialog.eu/Google_returns_to_anti-competitive_behavior-ESD_26042023.pdf
>> . This document is still prominent on the ESD web site, in spite of the
>> fact that the Bundeskartellamt (Germany's antitrust agency, as I understand
>> it) terminated its administrative proceedings against Google related to
>> this matter, finding in the matter of reduced certificate duration that
>>
>> Overall the security level of the certi-fication process was increased,
>> from which the internet users and ultimately also the website operators
>> benefited, as long as the reduction of the validity periods did not
>> generally affect the purchase of certificates with a higher level of
>> authentication [ed: OV/EV certificates], for which there is however no
>> indi-cation.
>>
>>
>>
>> (
>> https://www.bundeskartellamt.de/SharedDocs/Entscheidung/EN/Fallberichte/Missbrauchsaufsicht/2022/B7-250-19.html
>> on page 7)
>>
>>
>>
>> The ESD site makes claims about this antitrust agency report that simply
>> do not accord with a clear reading of the case summary. It is difficult to
>> view this in a charitable light.
>>
>>
>>
>> Additionally, in campaigning for EIDAS' possibility for mandatory
>> inclusion of certain roots, which would eliminate browsers' ability to make
>> their own informed trust decisions as they deem best for their users, the
>> ESD cites Mozilla having a small market share as reason for disregarding
>> its (opposed) position:
>>
>>
>>
>> (Note: Mozilla is the only browser who has signed this “industry
>> statement” – none of the other browsers are included. According to
>> statcounter.com, Mozilla Firefox has only a 3.0% world market share,
>> down from 30% in prior years.)
>>
>>
>>
>>
>> https://www.european-signature-dialog.eu/ESD_experts_support_trilogue_Art.45_results-6nov2023.pdf
>> (page 1)
>>
>>
>>
>> We have recently seen, and as a community considered unacceptable, CAs
>> failing to respond appropriately to incidents until one of the "larger"
>> browsers' representatives appeared. Votes in the CAB/F and CCADB are not
>> weighted by market share by either CAs or browsers, and nor should they be.
>> *That* would be ripe for abuse of market power, which is why it's
>> imperative that CAs take all other CAs and browser members equally
>> seriously. This statement puts into serious question how a CA that endorsed
>> the ESD's beliefs would respond to incidents raised by Mozilla or its
>> community. We have seen recently that such incidents and attention can be
>> very important for detecting and reacting to CA malfeasance, and we have
>> seen how another member of this organization (Entrust) indeed displayed
>> this exact behaviour, to the detriment of the web PKI.
>>
>>
>>
>> This document also states without elaboration or supporting evidence that
>> browsers have "abused their monopoly regulatory powers in the past", and
>> describe a 90-day lifetime limitation as being them abusing such power
>> "again". (p4)
>>
>>
>>
>> I have significant concerns about inclusion of a CA whose director shares
>> the beliefs and endorses the practices of this organization. Their policies
>> and advocacy are actively hostile to the integrity of the web PKI, and the
>> governance of the web PKI's institutions.
>>
>>
>>
>> Questions for D-Trust:
>>
>> - does D-Trust, or its director, agree with the positions of the ESD on
>> matters of certificate duration, and the relevance of market share to the
>> validity of different browser positions on web PKI matters?
>>
>> - if not, why does D-Trust remain a member and allow its director to be
>> listed as endorser of this organization?
>>
>> - did D-Trust endorse these positions when they were being established by
>> the ESD, or oppose them? Please provide examples of the positions taken, if
>> opposed.
>>
>> - specifically, does D-Trust feel that reduced certificate duration
>> represents a security hazard, or antitrust concern? What is D-Trust's
>> position on certificate duration as a tool for reducing the impact of
>> misissuance or certificate compromise?
>>
>> - specifically, when does D-Trust feel that it is appropriate to consider
>> browser market share when determining the validity of said browser's
>> position (on policy or an incident)? How would its response differ between
>> a concern raised by Chrome, versus one raised by Mozilla?
>>
>>
>>
>> Thank you in advance for your thorough response,
>>
>>
>>
>> Mike
>>
>>
>>
>>
>>
>> On Thu, Sep 12, 2024 at 9:15 AM 'Ryan Dickson' via CCADB Public <
>> [email protected]> wrote:
>>
>> All,
>>
>>
>>
>> This email commences a six-week public discussion of D-Trust’s request to
>> include the following certificates as publicly trusted root certificates in
>> one or more CCADB Root Store Member’s program. This discussion period is
>> scheduled to close on October 24, 2024.
>>
>>
>>
>> The purpose of this public discussion process is to promote openness and
>> transparency. However, each Root Store makes its inclusion decisions
>> independently, on its own timelines, and based on its own inclusion
>> criteria. Successful completion of this public discussion process does not
>> guarantee any favorable action by any root store.
>>
>>
>>
>> Anyone with concerns or questions is urged to raise them on this CCADB
>> Public list by replying directly in this discussion thread. Likewise, a
>> representative of the applicant must promptly respond directly in the
>> discussion thread to all questions that are posted.
>>
>> *CCADB Case Number: *00001362
>> <https://ccadb.my.salesforce-sites.com/mozilla/PrintViewForCase?CaseNumber=00001362>
>> and 00001363
>> <https://ccadb.my.salesforce-sites.com/mozilla/PrintViewForCase?CaseNumber=00001363>
>>
>> *Organization Background Information (listed in the CCADB):*
>>
>>    - *CA Owner Name:* D-Trust
>>    - *Website: *https://www.d-trust.net/en
>>    - *Address: *Kommandantenstr. 15, Berlin, 10969, Germany
>>    
>> <https://www.google.com/maps/search/Kommandantenstr.+15,+Berlin,+10969,+Germany?entry=gmail&source=g>
>>    - *Problem Reporting Mechanisms: *
>>    https://www.d-trust.net/en/support/reporting-certificate-problem
>>    - *Organization Type: *Government Agency
>>    - *Repository URL: *https://www.bundesdruckerei.de/en/Repository
>>
>> *Certificates Requesting Inclusion:*
>>
>>
>>
>>    1. *D-TRUST EV Root CA 2 2023:*
>>
>> o   *Certificate download links:* CA Repository
>> <https://www.d-trust.net/cgi-bin/D-TRUST_EV_Root_CA_2_2023.crt> / crt.sh
>> <https://crt.sh/?q=8E8221B2E7D4007836A1672F0DCC299C33BC07D316F132FA1A206D587150F1CE>
>>
>> o   *Use cases served/EKUs:*
>>
>> §  Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
>>
>> §  Client Authentication 1.3.6.1.5.5.7.3.2
>>
>> o   *Test websites:*
>>
>> §  Valid: https://certdemo-ev-valid-rsa.tls.d-trust.net/
>>
>> §  Revoked: https://certdemo-ev-revoked-rsa.tls.d-trust.net/
>>
>> §  Expired: https://certdemo-ev-expired-rsa.tls.d-trust.net/
>>
>> o   *Replacement notice:* D-Trust has communicated intent to use this
>> applicant root to replace D-TRUST Root Class 3 CA 2 EV 2009
>> <https://crt.sh/?q=EEC5496B988CE98625B934092EEC2908BED0B0F316C2D4730C84EAF1F3D34881>
>> in some root stores, with the replacement taking place approximately on
>> September 1, 2026.
>>
>>
>>
>> *2.  **D-TRUST BR Root CA 2 2023:*
>>
>>    - *Certificate download links:* CA Repository
>>    <https://www.d-trust.net/cgi-bin/D-TRUST_BR_Root_CA_2_2023.crt> /
>>    crt.sh
>>    
>> <https://crt.sh/?q=0552E6F83FDF65E8FA9670E666DF28A4E21340B510CBE52566F97C4FB94B2BD1>
>>    - *Use cases served/EKUs:*
>>
>>
>>    - Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
>>       - Client Authentication 1.3.6.1.5.5.7.3.2
>>
>>
>>    - *Test websites:*
>>
>>
>>    - Valid: https://certdemo-dv-valid-rsa.tls.d-trust.net/
>>       - Revoked: https://certdemo-dv-revoked-rsa.tls.d-trust.net/
>>       - Expired: https://certdemo-dv-expired-rsa.tls.d-trust.net/
>>
>>
>>    - *Replacement notice:* D-Trust has communicated intent to use this
>>    applicant root to replace D-TRUST Root Class 3 CA 2 2009
>>    
>> <https://crt.sh/?q=49e7a442acf0ea6287050054b52564b650e4f49e42e348d6aa38e039e957b1c1>
>>    in some root stores, with the replacement taking place approximately on
>>    September 1, 2026.
>>
>>
>>
>> *Existing Publicly Trusted Root CAs from D-Trust:*
>>
>>    1. *D-TRUST BR Root CA 1 2020:*
>>
>>
>>    - *Certificate download links:* (CA Repository
>>    <https://www.d-trust.net/cgi-bin/D-TRUST_BR_Root_CA_1_2020.crt> /
>>    crt.sh
>>    
>> <https://crt.sh/?q=E59AAA816009C22BFF5B25BAD37DF306F049797C1F81D85AB089E657BD8F0044>
>>    )
>>    - *Use cases served/EKUs:*
>>
>> §  Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
>>
>> §  Client Authentication 1.3.6.1.5.5.7.3.2
>>
>> o   *Certificate corpus:* here
>> <https://search.censys.io/search?resource=certificates&q=E59AAA816009C22BFF5B25BAD37DF306F049797C1F81D85AB089E657BD8F0044%09+and+labels%3Dever-trusted>
>> (Censys login required)
>>
>> o   *Included in:* Google Chrome, Mozilla
>>
>> *2.  **D-Trust SBR Root CA 1 2022:*
>>
>>    - *Certificate download links:* (CA Repository
>>    <http://www.d-trust.net/cgi-bin/D-Trust_SBR_Root_CA_1_2022.crt> /
>>    crt.sh
>>    
>> <https://crt.sh/?q=D92C171F5CF890BA428019292927FE22F3207FD2B54449CB6F675AF4922146E2>
>>    )
>>    - *Use cases served/EKUs: *
>>
>>
>>    - Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4;
>>       - Client Authentication 1.3.6.1.5.5.7.3.2;
>>       - Document Signing AATL 1.2.840.113583.1.1.5;
>>       - Document Signing MS 1.3.6.1.4.1.311.10.3.12
>>
>>
>>    - *Certificate corpus:* N/A
>>    - *Included in:* Mozilla
>>
>> *3.  **D-Trust SBR Root CA 2 2022:*
>>
>>    - *Certificate download links:* (CA Repository
>>    <http://www.d-trust.net/cgi-bin/D-Trust_SBR_Root_CA_2_2022.crt> /
>>    crt.sh
>>    
>> <https://crt.sh/?q=DBA84DD7EF622D485463A90137EA4D574DF8550928F6AFA03B4D8B1141E636CC>
>>    )
>>    - *Use cases served/EKUs:*
>>
>>
>>    - Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4;
>>       - Client Authentication 1.3.6.1.5.5.7.3.2;
>>       - Document Signing AATL 1.2.840.113583.1.1.5;
>>       - Document Signing MS 1.3.6.1.4.1.311.10.3.12
>>
>>
>>    - *Certificate corpus:* N/A
>>    - *Included in: *Mozilla
>>
>> *4.  **D-TRUST EV Root CA 1 2020:*
>>
>>    - *Certificate download links:* (CA Repository
>>    <https://www.d-trust.net/cgi-bin/D-TRUST_EV_Root_CA_1_2020.crt> /
>>    crt.sh
>>    
>> <https://crt.sh/?q=08170D1AA36453901A2F959245E347DB0C8D37ABAABC56B81AA100DC958970DB>
>>    )
>>    - *Use cases served/EKUs: *
>>
>> §  Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
>>
>> §  Client Authentication 1.3.6.1.5.5.7.3.2
>>
>> o   *Certificate corpus:* here
>> <https://search.censys.io/search?resource=certificates&q=08170D1AA36453901A2F959245E347DB0C8D37ABAABC56B81AA100DC958970DB+and+labels%3Dever-trusted>
>> (Censys login required)
>>
>> o   *Included in:* Google Chrome, Mozilla
>>
>>
>>
>> *5.  **D-TRUST Root CA 3 2013:*
>>
>>    - *Certificate download links:* (CA Repository
>>    <https://www.d-trust.net/cgi-bin/D-TRUST_Root_CA_3_2013.crt> / crt.sh
>>    
>> <https://crt.sh/?q=A1A86D04121EB87F027C66F53303C28E5739F943FC84B38AD6AF009035DD9457>
>>    )
>>    - *Use cases served/EKUs: *
>>
>> §  Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4;
>>
>> §
>>
>>

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