On Monday, April 24, 2017 at 9:58:29 PM UTC-7, Jakob Bohm wrote:
> On 25/04/2017 05:04, Ryan Sleevi wrote:
> > On Mon, Apr 24, 2017 at 9:42 PM, Jakob Bohm via dev-security-policy <
> > dev-security-policy@lists.mozilla.org> wrote:
> >
> >> On 25/04/2017 03:10, Peter Kurrasch wrote:
> >>
> >>> Fair enough. I propose the following for consideration:
> >>>
> >>> Prior to ‎transferring ownership of a root cert contained in the trusted
> >>> store (either on an individual root basis or as part of a company
> >>> acquisition), a public attestation must be given as to the intended
> >>> management of the root upon completion of the transfer. "Intention" must
> >>> be one of the following:
> >>>
> >>> A) The purchaser has been in compliance with Mozilla policies for more
> >>> than 12 months and will continue to administer (operate? manage?) the
> >>> root in accordance with those policies.
> >>>
> >>> B) The purchaser has not been in compliance with Mozilla policies for
> >>> more than 12 months but will ‎do so before the transfer takes place. The
> >>> purchaser will then continue to administer/operate/manage the root in
> >>> accordance with Mozilla policies.
> >>>
> >>> How about:
> >>
> >> B2) The purchaser is not part of the Mozilla root program and has not
> >> been so in the recent past, but intends to continue the program
> >> membership held by the seller.  The purchaser intends to complete
> >> approval negotiations with the Mozilla root program before the transfer
> >> takes place.  The purchaser intends to retain most of the expertise,
> >> personnel, equipment etc. involved in the operation of the CA, as will
> >> be detailed during such negotiations.
> >>
> >> This, or some other wording, would be for a complete purchase of the
> >> business rather than a merge into an existing CA, similar to what
> >> happened when Symantec purchased Verisign's original CA business years
> >> ago, or (on a much smaller scale) when Nets purchased the TDC's CA
> >> business unit and renamed it as DanID.
> >>
> >
> > Why is that desirable? If anything, such acquisitions seem to be more
> > harmful than helpful to the CA ecosystem. That is, why _wouldn't_ a merge
> > be useful/desirable? What problems are you attempting to solve?
> >
> 
> Look at my two examples of past acquisitions.  As far as I remember, in
> neither case was the purchasing security company previously a trusted
> CA, and they took over practically the whole operation with no initial
> changes besides a name change.
> 
> Another variant of this scenario is when a CA restructures its formal
> ownership structure, such as inserting or removing one or more levels
> of companies between the ultimate owners and the CA operations
> activity.  In many cases this would technically be an acquisition by a
> new company that isn't a CA itself (as the acquiring company would
> often be an empty shell).  One example would be the recent creation of
> GTS from part of Google Inc, since GTS was a new company with no past
> CA activity, while the acquired Google division had a past as a SubCA
> and a recently acquired root cert.
> 
> 
> Enjoy
> 
> Jakob
> -- 
> Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
> Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10
> This public discussion message is non-binding and may contain errors.
> WiseMo - Remote Service Management for PCs, Phones and Embedded

Jakob,

I would add that in cases where CA organizations are acquired outright and the 
staff and infrastructure are retained it is often only for a limited period of 
time. 

In other words, the acquisition takes place and then after some relatively 
short period of time we see the acquirer try to:
- align operations with other parts of the business,
- achieve cost savings,
- improve technology, performance, scale and disaster recovery ability.

These all tend to result in a reboot of "what was there" prior to the 
acquisition.

In these situations dislocated key staff often finds new roles at another CA or 
move on to non-ca related roles and sleep better ;)

Ryan
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