I think we're well past the point where a "do-over" can be considered a 
reasonable remedy. The problem is not simply one in which certs were issued 
improperly nor is it simply one in which ‎there were mistakes in the CA 
infrastructure. Such problems, I think, could fall under a category where 
starting over with new roots, new audits, etc. would seem acceptable. 

Rather, what we have here is basically a rogue operator that has threatened the 
trust and integrity of the global PKI system. Their conduct‎ has undermined 
efforts to establish and maintain security on the Internet (e.g. backdating 
SHA-1 certs). Their conduct has flaunted rules and regulations for reasons that 
are still to this day not fully understood (e.g. ownership and problems with 
the auditng). Their conduct has caused undue consternation to web site owners 
(e.g. github) due to cert mis-issuance. Their conduct has put their own 
customers in a difficult position as they must now consider obtaining new certs 
for their websites.

Starting over with new roots won't remedy these problems.

  Original Message  
From: Stephen Schrauger
Sent: Tuesday, September 27, 2016 7:32 AM
To: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: WoSign and StartCom

> > Should StartCom/WoSign be permitted to re-apply using the same roots,
> > or would they need new roots?
> 
> New roots. Considering the extent to which StartCom/WoSign have
> mismanaged things, there could be further misissued certificates
> chaining to their roots that we don't know about. The only way to
> protect the ecosystem from such certificates is to require new roots -
> roots that have only ever operated under the new audits that will be
> required by Mozilla.
> 
> Regards,
> Andrew

I agree that they should need new roots. But on top of the points Andrew makes, 
it would also require StartCom and WoSign to get cross-signed if they wish to 
continue supporting older devices that lack their new roots. 

They would have to regain the trust of another root CA who would be willing to 
cross-sign their new roots. Or else StartCom and WoSign would have to accept 
that new certificates created under their new root may not work on older 
devices, since older computers and embedded devices aren't always able to 
update their root stores.

Assuming they want new certificates to work on older devices, I imagine the 
need to be cross-signed would create another point of trust, since another CA 
willing to cross-sign would do their own audit and have added requirements.
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