Hi Arno and Martin,

> On Aug 14, 2017, at 11:44, Arno Fiedler <arno.fied...@outlook.com> wrote:
> 
> Dear Forum,  
> 
> since the 07-07-2017, all new issued D-TRUST TLS-Certificates have at least 
> 64 bits of entropy in the serial number.
> 
> Since 01-12-2016 D-TRUST TLS certificates requested via our enterprise 
> platform have a serial number which includes at least 64 bits of entropy. We 
> informed the CA-Program Manager about the 3 Month delay in moving the entropy 
> from the "DNqualifier” to the “SerialNumber” via eMail on 27-10-16.

Does this mean that you knew you would not be complying with Ballot 164 / BRs 
1.3.7 by the effective date of 2016-09-30? When did you realize this? Did you 
receive permission for this non-compliance from the relevant Application 
Software Suppliers, including Mozilla?

> Between 2012 and 06-07-2017 we still produced a smaller number of 
> certificates using our retail platform with additional entropy in the 
> “DNqualifier” field instead of the serial number field, because our certified 
> third party software was not able to handle long serial numbers earlier.  We 
> defined this issue as minor nonconformity, because the requirement for 
> entropy in the certificate was fulfilled.

What other issues have you defined as a "minor nonconformity"?

> On 20-07-17 Mozilla asked D-TRUST for clarification, due to the holiday 
> period this message reached us on 07-08-17, AF answered on 08-08-17 and 
> 10-08-17: “the certificate has 64 bits of entropy in the "DNqualifier" field 
> instead of the serial number field. Since 2012 we used this way of adding 
> random bits to certificates to mitigate preimage attacks. From a security 
> perspective the amount of Entropy in the certificate should be reasonable”.
> 
> On 10-08-2017 we got the information, that we issued in the Individual 
> Certificate Registration process a certificate with less entropy than 64 bit, 
> Jonathan reported “The DNqualifier appears to have a 33-bit number, not a 
> 64-bit number”.
> 
> On the 11-08-2017 we defined this case as a major issue, because our internal 
> examinations confirmed, that just using numeric characters causes entropy 
> less than 64 bit.
> 
> The review with our tool “PKI-watcher” gave the following result of effected 
> certificates:
>     D-TRUST SSL Class 3 CA 1 2009 (607) 
>     D-TRUST SSL Class 3 CA 1 EV 2009 (63)

To provide transparency, can you please add all of these certificates to at 
least one CT log and post the serial numbers, certificate fingerprints, or 
crt.sh IDs?

Jonathan

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