On Wednesday, August 31, 2016 at 8:05:57 PM UTC-7, Richard Wang wrote:
> First, please treat WoSign as a global trusted CA, DON'T stamp as China CA. 
> We need a fair treatment as other worldwide CAs that I am sure WoSign is not 
> the first CA that have incident and not the serious one;

I would have hoped, through all of this, that you would have come to realize 
the seriousness and gravity of the multiple problems that WoSign has had over 
the past 18 months, rather than continue to dismiss it.

You misissued certificates to people who were not authorized. Repeatedly. In 
multiple separate instances.

You have had multiple issues with adhering to the Baseline Requirements, and 
those have not been disclosed, to your auditors or browsers. Consider Incident 
-1, which was not listed here in this thread yet, on April 4, 2015, which 
caused you to update your CPS ( 
http://www.wosign.com/policy/wosign-policy-1-2-10.pdf ) to correct several 
issues that Google reported to you regarding non-compliance to your stated 
policies and to the BRs.

Ultimately, CAs are based on trust:
- Trust that they're performing the necessary validation and vetting procedures
- Trust that they are securing their internal systems from both internal and 
external threats
- Trust that they understand the seriousness of their role as a provider of 
global certificates, any of which might be used to compromise or attack users, 
and take adequate steps to ensure the correctness of those operations.

Your responses, unfortunately, have done little to instill or affirm that the 
trust is well placed. Even more so, you're a CA authorized to issue the most 
rigorous certificates available (Extended Validation), and so the bar is set 
even higher for your operational controls and processes!

- You failed to understand the gravity of the misissuance, and thus failed to 
revoke these certificates. I would argue this constitutes a further BR 
violation itself, per Section 4.9.1.1 of the BRs ( 
https://cabforum.org/wp-content/uploads/CA-Browser-Forum-BR-1.3.8.pdf ), in 
particular, Items 4 and Items 9 in that list, but would be curious if you 
disagree.
- You have repeatedly suggested this was an honest mistake, suggesting it was a 
singular issue, when the reality is that it is a pattern of mistakes that have 
spanned over a year and have led to multiple misissued certificates.
- These incidents - including the issue with the CPS page - suggest a software 
development methodology that fails to adequately ensure the robustness of the 
systems, and fails to understand the security risks that must be mitigated in 
such systems.

When there are concerns that undermine trust, it's important to engage to 
restore trust, and so I truly appreciate your involvement in these discussions, 
and your efforts to restore that trust. And while it's understandable that, in 
any security incident, there will be disagreements regarding severity or 
impact, it's vitally important for an entity whose product depends on trust 
takes steps to understand the issues, understand the perspectives, and takes a 
careful look to understand why so many people are disagreeing with the risk 
assessment or mitigation strategy.

> Third, I believe no one dare to say his system no bug, WoSign admitted we 
> have system bug that issued the wrong certificate and fixed.

Alternatively, WoSign dismissed the need to revoke the certificates, despite 
knowing that they were not validated according to the BRs, routinely violated 
their CPS, failed to notify either browsers or their auditors of these issues, 
all while violating other provisions of the Baseline Requirements that were 
disclosed - such as duplicate serials and SHA-1 certificates.

This is a vast departure from, say, the thread last month - 
https://groups.google.com/d/msg/mozilla.dev.security.policy/9QKw1C3m4Lo/nkg1rcJyAgAJ
 - and shows how significant the gap in perception and user trust can be, based 
on how a CA handles an incident and the subsequent public discussion.

> This is why WoSign is the first CA in the world for volunteering to "Require 
> CT", we like to use CT mechanism to find out the bug quickly and reduce the 
> lost to minimum, we logged all issued certificate to CT log server and 
> embedded SCT data to certificate since July 5th. Thanks for Google invent so 
> good transparency system.

And yet, although you've committed to logging your certificates, your logging 
has failed to abide by the one policy that exists for CT logging - the Chromium 
CT policy ( 
https://www.chromium.org/Home/chromium-security/certificate-transparency ).

While it's laudable that you're logging your certificates at all, there's two 
important pieces being omitted here:
- By only logging to Google logs, you're not necessarily improving trust, 
because now the burden is to trust Google.
- This is an issue I personally informed you about and discussed at length with 
you on May 25, 2016.

For example, as highlighted in the message you're replying to, if Chrome were 
to do what you requested - and require CT for WoSign certificates - few to none 
of the WoSign certificates issued since would be trusted.

Consider this Precertificate - https://crt.sh/?id=30466652 - and its associated 
certificate, https://crt.sh/?id=30468277 - which you only logged to Google's 
Pilot and Aviator logs. That means that in order to trust WoSign certificates, 
you'd have to trust Google as a single point of trust - which, as I highlighted 
earlier, is something even Google isn't willing to ask of the public.

> Finally, I am very sorry to all browsers that we don't execute the incident 
> report policy properly, WoSign get a deep lesson for how to deal with this 
> kind of incident now, I wish everyone give us a chance to be a good boy, at 
> least one-time chance.  Thanks a million.

Don't you believe the evidence shows you've already been given multiple 
chances, and yet continue to unfortunately find new and distinct ways to 
misissue certificates? At what point should the community say that enough is 
enough? That's fundamentally the question here.

I realize this may seem like a debate between there "three incidents" (although 
there have been at least two more BR violating incidents, as highlighted in 
this message) and "four incidents" (giving you one more chance), but a key goal 
of this thread was to question whether or not it was believed that WoSign would 
improve.
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