Hello, I am the domain owner of debigare.com. I would like to make you aware 
that Comodo CA took more than 5 days to revoke certificates they had signed for 
my domain and subdomains after requesting them to do through their sslabuse 
email address, past the 24 hours maximum mentioned in the Baseline Requirements 
as stipulated in section 4.9.1.1.

For context, I was previously using Cloudflare's Universal SSL feature, but 
disabling it did not revoke the old certificates that had not yet expired, but 
simply removed them from its system, and some of the certificates were still 
valid for more than 6 months.

I first attempted to contact Cloudflare's support to ask them to revoke the 
certificates themselves on September 6 at 7:43 UTC. This only led to irrelevant 
responses and confused customer support agents that had no idea what I was 
talking about, and this appeared to go nowhere. I eventually got a response 
from them on September 11 at 5:53 UTC that they would request CAs to perform 
the revocation, but that was after I did so myself, and I never got a status 
report back afterwards.

There were two CAs affected by this issue. The vast majority of certificates 
were signed by Comodo CA, and the rest by DigiCert. I did not run into any 
issues with DigiCert (they in fact proactively checked with Cloudflare my claim 
and revoked the certificates before I even had the chance to attempt their 
domain ownership challenge), but Comodo CA was another story entirely.

My first request to Comodo CA to revoke the certificates for debigare.com and 
all of its subdomains was on September 8 at 4:37 UTC. I did not get a reply 
until September 9 at 15:53 UTC stating that the certificates have been revoked. 
Not only was this past the 24 hours requirement, but it was also false, as only 
the most recent certificates had been revoked, not all of them. I mentioned to 
them their mistake on September 10 at 5:55 UTC with a full list of affected 
certificates just in case my initial request was unclear to them, and never got 
a reply back. I did, however, notice that the certificates eventually got 
revoked on September 13 at 16:04 UTC according to their Certificate 
Transparency logs, a fact that I only discovered on September 15. Assuming the 
log is correct, that would be a delay of more than 3 days after notifying them 
of the incomplete revocation, more than 5 days after my initial request to 
them, and more than a week until I finally noticed the problem was fixed. It's 
also worth noting that throughout this entire series of events, Comodo CA never 
requested proof of domain ownership beyond the evidence I initially provided, 
so that cannot explain the delays.

One detail that I'm not sure about is why my initial evidence for domain 
ownership was apparently sufficient for Comodo CA but not for DigiCert. On this 
regard, the only evidence I provided to both of them was that the email address 
I used to contact them matched the contact information on my website. (My 
emails were protected with SPF, DKIM and DMARC for authenticity.) For some 
reason, DigiCert believed that this evidence did not met the Baseline 
Requirements for my request, a claim that I am currently unable to verify as I 
cannot find anything of the sort in them.

You can read the full story on my blog, which I hope will be sufficient to 
prove my identity: 
https://www.debigare.com/4-unexpected-issues-i-encountered-upon-switching-web-hosts/

I can also provide a full copy of the email exchange I had with Comodo CA as 
evidence on request.

Guillaume Fortin-Debigaré
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