All,

On August 28, 2023, we began a six-week, public discussion[1] on the
following root CA certificates issued by Commscope:

   1.

   CommScope Public Trust RSA Root-01:

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


   1.

   CommScope Public Trust RSA Root-02:

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


   1.

   CommScope Public Trust ECC Root-01

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


   1.

   CommScope Public Trust ECC Root-02

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

The public discussion period ended today, October 10, 2023.

Summary of Questions and Responses

One question asked about the particular value that Commscope would add to
the web PKI.

Commscope replied that it had served companies like Motorola, Broadcom,
Verizon, and T-Mobile and that it had manufacturing experience provisioning
solutions for billions of IoT devices. In addition to device manufacturing,
Commscope said that it would serve “device manufacturers and operators of
device fleets, whose requirements are not the same as typical web site
operator.”

One commenter noted that embedded systems tend to run out-of-date software
that is never updated and that using publicly-trusted certificates with
embedded systems harms the WebPKI by holding back progress and that CAs
will sometimes misissue certificates to older devices for compatibility
reasons.

Follow-up questions from two commenters asked how CommScope would ensure
that devices with certificates would stay up-to-date with TLS and WebPKI
ecosystem requirements and how certificates on such devices would be
replaced in the event that an arbitrarily large number of certificates
needed to be revoked within the timelines specified by the CA/Browser
Forum’s Baseline Requirements.

Commscope responded that it participates in CA/Browser Forum discussions
and monitors root programs for rule changes and would take a proactive
approach to compliance with industry standards. They also said that they
would ensure compliance by notifying device manufacturers and service
providers and assist them with updates as needed. Commscope also claimed to
have the capacity for bulk, high-volume certificate revocation and
automated certificate replacement on devices.

Another comment pointed out that Commscope had issued test certificates
with empty SCT extensions.

Commscope explained the difficulty experienced in submitting certificates
to CT logs, and it agreed to revoke and replace the certificates in
question. It also filed an incident report.[2]

One commenter asked whether Commscope would be issuing certificates to
other entities or only to its own products.

Commscope said that it would be issuing certificates to other entities.

Another question was whether Commscope would use ACME?

Commscope said that it supported certificate enrollment using ACME and
CMPv2 and would use them if the deploying organization required their use.

Another question asked about the domain validation methods that Commscope
would use.

Commscope said that it currently uses email to the Domain Contact (BR §
3.2.2.4.2) and DNS Change (BR § 3.2.2.4.7) to perform domain validation,
but that it had the ability to support ACME (“Agreed-Upon Change to Website
– ACME” method (BR § 3.2.2.4.19)) when the business need arises.

Conclusion

We thank the community for its review and consideration during this period.
Root Store Programs will make final inclusion decisions independently, on
their own timelines, and based on each Root Store Member’s inclusion
criteria. Further discussion may take place in the independently managed
Root Store community forums (i.e., MDSP).

Ben

[1]
https://groups.google.com/a/ccadb.org/g/public/c/HVwBXDw6GnU/m/1LsNC19RAQAJ
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1852404#c7

On Thu, Oct 5, 2023 at 10:44 AM 'So, Nicol' via CCADB Public <
public@ccadb.org> wrote:

> On Tue, 03 Oct 2023 05:41:50 -0700, Seo Suchan wrote:
>
>
>
> > what kind of validation methods you'll use for  your certificates? as in
> allowed method numbered in ca/b br? as you said will use acme I guess
> 3.2.2.4.7 /19/20 , right?
>
>
>
> As stated in our CP/CPS, CommScope currently support 2 methods for domain
> control validation:
>
>
>
>    - Email to Domain Contact (BR § 3.2.2.4.2)
>    - DNS Change (BR § 3.2.2.4.7)
>
>
>
> We have the technical capability to support ACME’s automated domain
> validation methods, but we currently don’t offer them. (ACME can be used
> with external account binding and have domain validation performed outside
> the protocol.) Going forward, we will support the “Agreed-Upon Change to
> Website – ACME” method (BR § 3.2.2.4.19) when the business need arises.
>
>
>
> Nicol So
>
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>

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