Thanks Nick.  I'm missing something on this, so I appreciate the help so
far. I replied to each section.

Perhaps you have confused transitivity with commutativity or one of the
other simple properties. Transitivity is the property whereby if F(A,B) and
F(B,C) then F(A,C), for example the "greater than" binary relation is
transitive.
[JR] No confusion on what the arithmetic property, but I am having trouble
seeing how the transitive
trust applies to a self-signed and self-issued root with a publicly trusted
root.  Can you explain this more? 

The previously undisclosed certificate chains to a certificate which chains
to another certificate and so on until you reach one that is included in the
programme.  The Mozilla policy isn't trying to do anything very fancy here,
it's just spelling out how chains actually work, which is why it was a
concern that you seem so surprised this policy applies.
[JR] Well yeah - but this one is self-signed and self-issued, so how does it
chain? 

It seems _especially_ strange to object for this certificate that you had
never imagined it was necessary to disclose it, while perhaps half a dozen
similar certificates in the same family were previously disclosed. I would
suggest that rather than demonstrating DigiCert had no idea it was supposed
to disclose them, it instead indicates that DigiCert's processes for
actually ensuring this gets done are inadequate and so some random
proportion of sub-CAs may go undisclosed entirely by accident. That's not
good news.

[JR] No. We have a process for disclosing. We didn't issue the cert...
directly. This was issued by the Belgium government, who is obligated to
follow the policy themselves for all cross-signed certs.  However, this
isn't a cross-signed cert since it's self-signed.  We've never encountered
transitive trust as we don't reuse keys in our certs.  This is a unique
situation for us as it's a program that's long been deprecated that we
haven't been able to force migration from. 


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