> Yeah, I completely get how that would happen. I would just think this is
a good learning opportunity to protect against ambiguously written text by
giving a day's buffer.

I absolutely agree Eric, and this is the primary reason I'm sharing this
issue here.
I am playing the role of a CA and Browser user here, speaking on behalf of
our customer. Our customer is the party that eventually is affected by this
misunderstanding.

We placed a request with Comodo to get this certificate order refunded and
place a new order (as it stands today it's unusable and I assume we can't
reissue it with a 3 years length at this point). I'm confident that we'll
sort this out, but I wanted to bring up this issue to encourage less
ambiguous wording in the future.

-- Simone


On Sun, Apr 22, 2018 at 2:10 PM, Eric Mill <e...@konklone.com> wrote:

>
>
> On Sun, Apr 22, 2018 at 5:01 PM, Rob Stradling <r...@comodoca.com> wrote:
>
>> On 22/04/18 21:04, Eric Mill via dev-security-policy wrote:
>>
>>> On Fri, Apr 20, 2018 at 9:30 AM, Tim Shirley via dev-security-policy <
>>> dev-security-policy@lists.mozilla.org> wrote:
>>>
>>> First of all, it's important to distinguish between the BR r
>>>> But even if you accept my premise there, then you have to ask "in what
>>>> timezone?"  March 1 00:00:00 2018 GMT in North America is February 28.
>>>> So
>>>> I could see someone making the argument that issuance at that moment in
>>>> time is fine if the CA is in North America but it's mis-issuance if the
>>>> CA
>>>> is in Europe, since the requirements don't state that the measurement is
>>>> UTC.  This is why I'm not a fan of such precise enforcements of
>>>> date-related compliance.  There are a lot of different ways to interpret
>>>> dates/times, but none of the readings materially change the net effect
>>>> of
>>>> the rule.  That is, all readings change the max validity period to ~825
>>>> days (which itself is subject to debate as to its precise meaning in
>>>> terms
>>>> of seconds) within a day or two of each other.  So, enforcing the date
>>>> as
>>>> Mar 1 as opposed to Mar 2 doesn't seem to add a lot of value and leads
>>>> to
>>>> confusion like this.
>>>>
>>>
>>> I'm just going to double down on Matt's comment that the problem here
>>> doesn't seem to be in strictness of enforcement, but rather CAs leaving
>>> themselves no buffer zone.
>>>
>>
>> The problem here, IMHO, is that the BR requirement was poorly written.
>>
>> Whatever business advantage there is of giving
>>> customers that one last day to get 3-year certs, seems likely not as
>>> valuable as the certainty of avoiding giving those customers errors when
>>> the certs are used in major browsers.
>>>
>>
>> The certainty?  Hindsight is a wonderful thing.  When I wrote Comodo CA's
>> code to enforce the "after 1 March 2018" rule, this "certainty" did no
>> occur to me.  I simply read the BR requirement and then implemented code to
>> enforce it.
>
>
> Yeah, I completely get how that would happen. I would just think this is a
> good learning opportunity to protect against ambiguously written text by
> giving a day's buffer.
>
> Tim's time zone example is another good reason to give that buffer, even
> if the BR language made it clear whether it was > or >=. A tangentially
> similar comparison would be that in other systems I've built that structure
> search results and push notifications around dates, the only safe way to do
> it is to assign times as 12:00 UTC, even if that doesn't really accurately
> describe the time something happened, so that no matter what time zone
> someone is in, they're guaranteed to see it as the same day. It's worth the
> imprecision to create consistency.
>
>
>>
>>
>> -- Eric
>>>
>>>
>>>
>>>> On 4/19/18, 10:10 PM, "dev-security-policy on behalf of Simone Carletti
>>>> via dev-security-policy" <dev-security-policy-bounces+tshirley=
>>>> trustwave....@lists.mozilla.org on behalf of dev-security-policy@lists.
>>>> mozilla.org> wrote:
>>>>
>>>>      Hello,
>>>>
>>>>      I'm investigating an issue on behalf of a customer. Our customer
>>>> requested a multi-year certificate that was issued on March 1st by
>>>> Comodo.
>>>>
>>>>      Here's the certificate:
>>>>      https://crt.sh?id=354042595
>>>>
>>>>              Validity
>>>>                  Not Before: Mar  1 00:00:00 2018 GMT
>>>>                  Not After : May 29 23:59:59 2021 GMT
>>>>
>>>>      The certificate is currently considered invalid at least by Google
>>>> Chrome.
>>>>
>>>>      It's my understanding that Google Chrome uses a >= comparison,
>>>> which
>>>> effectively means certificates issued on March 1st are already subject
>>>> to
>>>> Ballot 193.
>>>>
>>>>      However, it looks like the interpretation of Comodo of Ballot 193
>>>> here
>>>> is based on a > comparison, since the certificate was issued with a 3y
>>>> validity.
>>>>
>>>>      BR 6.3.2 says:
>>>>
>>>>      > Subscriber Certificates issued after 1 March 2018 MUST have a
>>>> Validity Period no greater than 825 days.
>>>>      > Subscriber Certificates issued after 1 July 2016 but prior to 1
>>>> March 2018 MUST have a Validity Period no greater than 39 months.
>>>>
>>>>      I'd appreciate some hints about whether a certificate issued on
>>>> March
>>>> 1st should be considered subject to Ballot 193 or not.
>>>>
>>>>      Best,
>>>>      -- Simone
>>>>
>>>
>> --
>> Rob Stradling
>> Senior Research & Development Scientist
>> Email: r...@comodoca.com
>>
>
>
>
> --
> konklone.com | @konklone <https://twitter.com/konklone>
>
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