Martin is correct. This is not well-formed cert as per RFC 5280:

4.1.2.4.Issuer

The issuer field identifies the entity that has signed and issued the

certificate.The issuer field MUST contain a non-empty distinguished

name (DN)



4.1.2.6.Subject

The subject field identifies the entity associated with the public

carried in the subject field and/or the subjectAltName extension.

We issued 5280bis in part to accommodate DANE's use of ss certs. Please don't
provide examples that are obviously non-complaint relative to basic PKIX and
X.509 specs.

Steve
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