Well said, Andrew.  You've summarised the issue excellently.

- Matt

On Thu, May 19, 2016 at 03:19:13PM -0700, Andrew Ayer wrote:
> Kathleen,
> 
> I believe that certificate authorities should be content-neutral.  They
> should not be required to assess "misuse" or "fraud," nor be required
> to revoke certificates except upon request of the owner of a domain
> listed in the certificate.
> 
> Requiring CAs to police website content is incompatible with Mozilla's
> goal of deprecating non-secure HTTP.  Requiring HTTPS for all sites is
> only attainable if all sites can easily obtain certificates, and
> content policing by CAs undermines that.  As the operator of an
> automated certificate reseller, I have witnessed countless cases of
> certificate authorities flagging certificate requests as "High Risk"
> due to the DNS name being supposedly similar to a popular brand name.
> Without exception, every time has been a false positive.  The best
> outcome is a multi-hour delay as a human reviews the website, and the
> worst outcome is an outright rejection of the request.  Either way, it
> creates uncertainty: you don't know if or when you can get a
> certificate, which makes it hard to automate certificate deployment,
> which makes it hard to deploy HTTPS.  Given that CAs have only the
> DNS name on which to base their decision, a high false positive rate
> seems inevitable.
> 
> Requiring CAs to revoke certificates based on website content creates
> another way for websites to be taken offline.  What recourse does a
> site operator have when their certificate is erroneously revoked by a
> CA?  How can websites that host user-uploaded content operate? These
> are difficult questions which will need adequate answers if HTTPS is to
> become mandatory for all websites.  It would be much better if CAs
> weren't required to police content and instead focused solely on what
> certificates are meant to do: certify that a public key belongs to a
> particular entity.
> 
> Protecting users from malicious content should be left to the
> software processing the content (e.g. Firefox), which can do a better
> job than a CA ever could.  Firefox already uses Google Safe Browsing to
> protect users from phishing and malware.  It works for content
> delivered over both HTTPS and HTTP, doesn't suffer from the multi-day
> delay inherent with certificate revocation, and can operate on a
> per-file level, using the URL or the hash of the file.  Thus, a known
> malware file can be blocked even when it appears on a brand new domain,
> and if only a single file on a domain is malicious, only that file is
> blocked instead of the entire site, which would cause collateral damage
> in the case of a site like GitHub which serves user-uploaded content.
> 
> Regards,
> Andrew
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> 

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