On Tue, 23 Feb 2016 18:57:41 +0000
Gervase Markham <g...@mozilla.org> wrote:

> Please comment on whether this proposal seems reasonable, being aware
> of the short timelines involved.

I am opposed. There is no telling how many other organizations are in a
similar situation due to poor planning or "oversights" on their part,
and who will also want special treatment.  Granting this exception will
set an expectation that exceptions will be granted in the future and
therefore that deadlines and deprecations need not be taken seriously.
That would have a negative effect on efforts to move the security of
the Internet forward.

Multiple mistakes were made by Worldpay (using public roots, leaving
the transition to the last minute, and then forgetting to renew before
the sunset) and Symantec (failing to make sure their customer was
prepared).  They had ample opportunity to avoid a crisis. It is not
Mozilla's responsibility to dig them out of the hole they have dug for
themselves, and doing so is contrary to Mozilla's interest in keeping
the Internet secure.

Additionally, none of the stipulations in the proposal mitigate the
risk of SHA-1 issuance.  Disclosure and revocation do no good if an
undisclosed, unrevoked certificate (possibly with CA:TRUE) can be
collided with the disclosed and revoked certificate.

Regards,
Andrew
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