Here are my comments on this draft.  There is one that has broader
implications (*).  I'd like to see this addressed by the working group
(specifically, why is there a need for multiple attestation challenges).

Also, I recognize that I'm posting these during the holidays.  I certainly
don't expect authors to respond until after the new year.

Deb
----------------
Section 1, para 3:  'to be the most common use case'?  Seems ambitious.
How about, 'to be a common use case'.  Rationale:  why draw speculation
about whether 'most' is true?

Section 1, last para:  'at the time it was authored'  change to 'at
publication time of this specification'.

*Section 1, last para:  I am assuming that the authors believe the rats
work is substantially far into the future?  (Or why would we publish the
challenge device-attest-01 if the rats work would replace it?).  With any
'SHOULD' one needs to outline when one might ignore the SHOULD.

Section 5, token:  Please move the discussion on the generation of random
values to Security Considerations.  Also RFC 4086 is dated, please consider
something like what is specified in draft-ietf-tls-rfc8446bis, Appendix
C.1. [I recognize that this deviates from RFC 8555, but it is clearer to
move a longer discussion to Sec Consid.]

Section 6:  Please reference RFC8555 for other security considerations.

Section 7.3:  What is the bullet 'Change Controller' meant to accomplish?

Appendix A:  I recommend that we add an 'Operational Considerations'
section within the body of the specification (classically, just before Sec
Considerations). RFC 5706 (or draft-ietf-opsawg-rfc5706bis) has more
information on format and what might be included (most of which does not
apply to this draft).  I don't believe you need to do much more than move
the contents of the Appendix into the new section.

Acknowledgments:  TO DO.  Indeed.

Nits:
Section 1, last para:  s/widley/widely
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