On Thu, Mar 9, 2017 at 1:34 PM, Steve Medin via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> In the case of CrossCert, where we have evidence of failure to properly
> document their work, we are NOT relying on their previous work and have
> begun fully revalidating all active certificates. In the cases of the other
> 3 RAs, our focus is reviewing all of the work previously done to verify
> that it can, in fact, be relied upon and/or determine where full
> revalidation, without relying on the prior work of the RA, is warranted, if
> at all.
>

Steve,

While I appreciate your reply, I think it highlights precisely the concern
about whether or not Symantec is qualified and/or should be trusted to make
this determination, given that Symantec is in possession of documented
evidence from one of their other RA partners about a failure to properly
document their work and to ensure the authenticity of what was documented.

Given your reply above, I think it's reasonable for readers to conclude
that Symantec's Compliance Team, despite having been alerted to these
issues on February 8, and having been aware of them for far longer, has
decided that they are not significant. I'm not sure how such a conclusion
is consistent with the information provided, and eagerly await any
explanation Symantec may offer.

Further, you have acknowledged that at least one auditor lacked sufficient
skill and licensing to perform the audit. It is also clear that one or more
of these RA partners was not audited with respect to "WebTrust Principles
and Criteria for Certification Authorities - SSL Baseline with Network
Security", and as such, lacks effective demonstration of adherence to the
security-relevant Principles and Criteria contained therein, only having
produced audits to the effect of "WebTrust Principles and Criteria for
Certification Authorities".

As demonstrated by the historical audits, the issues presented issues span
multiple years, so even remediation plans that may have been effected for
one or more of these delegated third parties, such plans do not
retroactively 'correct' any misissuance or bad data logged in such systems.

Finally, I am uncertain how any of Symantec's proposal is consistent with
its CP/CPS, which incorporates the Baseline Requirements. In particular,
Symantec has now had six weeks, and still has failed to abide by the terms
of Section 4.9.1.1 regarding these 30,000 certificates.

Regardless of the next steps Symantec may take, I think it's reasonable to
suggest that these are all extremely important for members of the community
to carefully contemplate, and all of them rest specifically with actions
and statements made by Symantec since this investigation began, rather than
the RA partners.
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