This is just a reminder that this Public Discussion is scheduled to close 
next Tuesday, October 10, 2023.

On Wednesday, September 6, 2023 at 4:39:43 PM UTC-4 So, Nicol wrote:

> On Fri, 01 Sep 2023 08:19:04 -0700, Antonios Chariton wrote:
>
>  
>
> > Will you be a TLS Client Certificate-heavy CA, or will you issue mostly 
> Server certificates?
>
>  
>
> For the near term, we expect the certificates to be used mostly as server 
> certificates.
>
>  
>
> > Do you plan to offer certificates to other entities or will you only be 
> issuing certificates for your own products?
>
>  
>
> We plan to offer our service to external parties as well.
>
>  
>
> > You write:
>
>  
>
> >> CommScope is more than just a standard CA. With its wealth of 
> experience dealing with device manufacturing, deployment and operation, we 
> are also well positioned to serve device manufacturers and operators of 
> device fleets, whose requirements are not the same as typical web site 
> operators.
>
>  
>
> > Based on that, I wanted to ask: have you tried (or plan to use) ACME for 
> these types of operations? If not, what is preventing you from doing so?
>
>  
>
> We support certificate enrollment using ACME and CMPv2. We will use those 
> protocols if the deploying organization requires them.
>
>  
>
> > The WebPKI has evolved to serve website operators, and the vast amount 
> of requirements imposed on all of its CAs have been designed for browsers 
> and websites, so you may have to face challenging circumstances if you try 
> to deviate too far from that. Especially with IoT, where — as Andrew said — 
> revocation and renewal is difficult, especially at these volumes you 
> describe, every incident that occurs will be more difficult to deal with, 
> not just for CommScope, but potentially for other entities involved such as 
> user agents. CAs are also required to implement changes relatively quickly. 
> The typical time frame is either weeks or months. Does that match your 
> expectations and the lifecycle for software updates and changes to your 
> relying parties?
>
>  
>
> Not all revocation-triggering events will affect a large number of 
> devices, and not all issues are security-related and require a 24-hour 
> turnaround time. The devices that we expect to have publicly-trusted 
> certificates provisioned are typically managed devices. If there’s a common 
> cause that requires the certificates of multiple devices to be revoked, 
> determining the devices affected should not be a problem because of the 
> information maintained in the management system and in our own records. The 
> deploying organization can provide us with information about the devices 
> affected, we can quickly add the certificates to the CRL and the OCSP 
> responder.
>
>  
>
> Issues that would require a large number of certificates to be revoke are 
> also a possibility for CAs that serve primarily website operators. For 
> managed devices, there is usually a capability to automate and coordinate 
> the certificate replacement process, which may not be available when the 
> user base consists of website operators with diverse architectures and 
> varying degrees of automation.
>
>  
>
> We understand that the requirements on publicly-trusted certificates will 
> continue to evolve, and we accept that reality.
>
>  
>
> > It’s not clear to me what the purpose of this application is, but 
> perhaps you are limiting your flexibility quite a bit by going down that 
> path. I’m not saying you should, or shouldn’t, I just want to understand if 
> this is all clear from the beginning. You clearly have experience with 
> PKIs, so I just wanted to get your thoughts on the issues above.
>
>  
>
> There are use cases in which managed devices will need to accept 
> connections from devices not owned or controlled by the service provider. 
> Asking subscribers to configure the trust stores on their devices is either 
> technically not possible or unacceptable for other reasons. Being able to 
> issue publicly trusted certificates would enable CommScope to simplify the 
> solution architecture and offer a better solution to our customers.
>
>  
>
> Nicol So
>

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