Am Montag, 14. August 2017 18:44:59 UTC+2 schrieb Jonathan Rudenberg:
> 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?
Answer:
We realized that there were problems with the implementation of Ballot 164 in 
September 2016 and we informed the Rootstore/Browser Provider via email on 
2016-10-27 that we  would be delayed until December 2016.
We believed ourselves to be compliant with Ballot 164 from 2016-12-01 when we 
implemented it into our enterprise platform. However, on 2017-08-07, we 
received knowledge about the case.

> > 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"?
Answer:
We didn´t detect any other minor nonconformity. In general we work with an 
accreditation scheme based on ISO 27 and EN 319 403 to implement the 
requirements from Root-Policies, CA/B-Forum Guidelines, eIDAS-Regulation and 
ETSI Policies, there are defined audit procedures to recognize, control and 
remediate nonconformities under the supervision of the certification audit body
> 
> > 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?
Answer:
We have implemented the CT logs into our EV production process and are 
currently unaware about how to manually export specific certificates to a log; 
we will publish the affected certificate serial numbers immediately via *.csv. 
Please advise us about the receiver.
A new certificate – instead of “www.lbv-gis.brandenburg.de/lbvagszit” – has 
been issued, the old one is revoked.
Arno

> 
> Jonathan

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