Ryan,

Here is some more information to continue the discussion.

-          We will continue to post all certificates to CT logs so issuance can 
be monitored.

-          We will reduce validity period of OneClick certificates to 6 months.

-          We will work with the hosting providers (on a case by case basis) to 
implement processes and procedures which prevent the uploading and use of test 
certificates on user controlled shared IP addresses (similar to how LE worked 
with their larger customers to blocking acme.invalid from being used)

More below.

From: Ryan Sleevi [mailto:r...@sleevi.com]
Sent: Monday, January 15, 2018 4:56 PM
To: Doug Beattie <doug.beat...@globalsign.com>
Cc: r...@sleevi.com; mozilla-dev-security-pol...@lists.mozilla.org; Gervase 
Markham <g...@mozilla.org>; Wayne Thayer <wtha...@mozilla.com>
Subject: Re: Possible Issue with Domain Validation Method 9 in a shared hosting 
environment
As suggested, we encourage you to work on devising technical mitigations or 
alternative methods of validating such certificates that can meet the use case. 
We don't think that, as described, the OneClick method meets the necessary 
level of assurance, nor do the necessary level of mitigating factors exist, to 
consider such certificates trustworthy.

Ryan – I’m at a loss.  The security threat is that a user can request a 
certificate for a domain they don’t own from hosting companies that permit SNI 
mappings to domains the user doesn’t own or control.  This permits them to pass 
validation for a domain they don’t control that is on the same IP address as 
their legitimate site (or at least to which they have this level of SNI 
control).  We will verify that our OneClick customers will request certificates 
for domains the hosting company is actively managing for their users and not 
permit malicious actions (much like LE verifying that their hosting companies 
do not permit “acme.invalid” domains to be used).  This eliminates the problems 
of SNI being used as an avenue for domain validation for malicious actors.  Is 
this not sufficient for some reason?

Surely you agree that within non-shared hosting environments OneClick is not 
vulnerable and can be used.

No, it's not sufficient.

The failure mode unfortunately necessarily includes a failure by GlobalSign 
process and/or personnel, and in that failure mode, there are further no 
mitigating factors.

- If GlobalSign adds a vulnerable entity to their whitelist
  - The certificates issued will be valid for 1-3 years, leaving only the 
(broken) revocation system as recourse
We can and will reduce max validity to 6 months as a standard configuration 
option within our system.

  - There is no step organizations can take to pre-emptively mitigate the risk 
of GlobalSign adding to the whitelist (compared to, say, blocking .invalid)
Actually, there is and I apologize for not making this more clear before.  We 
have site operators that manage the issuance of certificates for their users.  
End users have no access to the issuance process, in uploading test 
certificates to their sites, or any involvement in the issuance process as this 
is automated by the site operators.  Given this approach is verified with the 
provider, we would propose whitelisting the account.

  - There is no ability for site operators to detect such situations. A 
consideration, not listed within the full set when discussing Let's Encrypt and 
the ACME TLS-SNI method, is that we have at least public commitment by Let's 
Encrypt and demonstrated evidence of sustained/long-term compliance with 
publicly disclosing all issued certificates ( as noted in 
https://letsencrypt.org/certificates/ ). While I realize you've offered to do 
so, I can find no evidence of GlobalSign doing so by default, and so this 
further adds to the risk calculus of a commitment to do something not yet 
practice and thus not yet consistently, reliably delivered on.
We currently include SCTs in all certificates we issue with the possible 
exception of some Enterprise customers that prefer to keep their OV 
certificates private (at least for now).  This has been configured since 
mid-November for all GlobalSign SSL products.

There is not, in our view, reason to accept this significantly greater 
(holistically considered) risk.

We're open to understanding whether GlobalSign has additional proposals how to 
mitigate this risk, given the set of concerns expressed - technical measures 
and policy measures. These may provide a path to allowing such issuance in the 
future, but we don't think that, given the holistic risk assessment, it's 
appropriate to allow it to immediately resume. We are keen to find solutions 
that work, as we understand that these can enable powerful new use cases, but 
we want to balance that with the risk posed.

I would encourage GlobalSign to consult Sections 3.2.2.4 and 3.2.2.5 to see if 
there are any other alternative methods to validating that might represent an 
appropriate balance. Given that these are posed as automated certificates, 
there seem that other methods may be suitable for the issuance of Domain 
Validated certificates - or, with care, Organizational Validated. If it truly 
is that none of these other methods (outside 3.2.2.4.9 and .10, and 
understandably the in-discussion-for-removal .1 and .5), are there steps that 
can be taken that provide concrete technical mitigations (ideally, through an 
opt-in technical signal by the site operator) that can reduce or eliminate this 
risk? Are there steps that can be taken with policy to similarly address the 
concerns?
There are some use cases where the provider does not control DNS or web site 
content, so moving to another method is not automated.  Certainly with the 
issues with methods 9 and 10 for shared IP address providers, we hope an 
alternate approach is identified and rolled out as a new BR Domain Validation 
method.

It's not that this is an unsolvable problem, but it's necessary to make further 
changes to mitigate and minimize the risk, and some of the major factors that 
contribute to that assessment have been shared.
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