I've held this discussion open for much longer than 3 weeks due to the
qualified audit reports that were received from Camerfirma. Since no
objections to the acquisition have been raised and the audit issues are
being discussed separately [1][2], I would like to close this discussion
and the corresponding bug [3] with a "positive conclusion" as required by
policy section 8.1 If you have concerns with this action, please respond by
the end of this week.

- Wayne

[1]
https://groups.google.com/d/msg/mozilla.dev.security.policy/Xmr13-ZK0_c/kiyqqk7hCQAJ
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1478933
[3] https://bugzilla.mozilla.org/show_bug.cgi?id=1463597

On Mon, Jul 30, 2018 at 5:47 PM Wayne Thayer <wtha...@mozilla.com> wrote:

> On Wed, Jul 18, 2018 at 1:56 PM Wayne Thayer <wtha...@mozilla.com> wrote:
>
>> I would like to begin a 3-week public discussion period for InfoCert's
>> acquisition of Camerfirma [1] as described in section 8.1 of the Mozilla
>> Root Store Policy. I believe that the intent of our policy in this scenario
>> is to identify and consider any risks introduced by the acquisition of
>> Camerfirma, and not to reevaluate Camerfirma's inclusion as if it were a
>> new CA. In that context, I will appreciate everyone's constructive input on
>> issues that may affect Mozilla's ongoing trust in InfoCert/Camerfirma. I
>> have included some additional information below.
>>
>> - Wayne
>>
>> Camerfirma answered the questions that I posed [2] about this acquisition
>> as follows:
>>
>> <snip>
>
>>
>> Camerfirma has one open compliance bug [5] requesting full audit
>> information for a subordinate CA.
>>
>> Camerfirma has supplied the audit information for this subordinate CA.
>
> Camerfirma also recently issued two intermediates that were not disclosed
> within the required week [8][9].
>
> Camerfirma's 2018 audit statements are overdue - the prior period ended on
>> 14-April 2017, and new statements have not yet been supplied to Mozilla.
>> Last year's statements are still listed on the Camerfirma website [6].
>>
>> Camerfirma has supplied their 2018 audit reports:
> https://bugzilla.mozilla.org/show_bug.cgi?id=1478933
>
> The WebTrust, BR, and EV reports all contain multiple qualifications. I
> would summarize the qualifications as follows:
> * Inconsistencies and omissions in CP/CPS documents which I would consider
> relatively minor.
> * Misissuances. The reports appear to be referring to those documented in
> bugs 1357067, 1390977, 1405815, 1431164, and 1443857.
> * Misissuance for "wildcard to immediate left of public suffix in SAN" was
> also reported. I found [10] but since those are for the .sener brand TLD,
> it is possible that Camerfirma issued them in compliance with BR 3.2.2.6.
> * Not meeting the BR requirement to revoke within 24 hours, presumably
> referencing bug 1390977.
> *The revocation time differs between the OCSP service and CRL for a few
> certificates, and the OCSP service responds "good" for some certificates
> revoked according to the CRL.
> * Failure to begin investigations of problem reports within 24 hours.
> * Failure to self-audit at least 3% of issued certificates each quarter.
>
> <snip>
>
> [1]
>> https://infocert.digital/infocert-underwrites-a-capital-increase-to-acquire-51-of-the-spanish-ac-camerfirma/
>>
> [2] https://bugzilla.mozilla.org/show_bug.cgi?id=1463597
>>
> [3] https://bugzilla.mozilla.org/show_bug.cgi?id=986854
>>
> [4]
>> https://groups.google.com/d/msg/mozilla.dev.security.policy/skev4gp_bY4/snIuP2JLAgAJ
>>
> [5] https://bugzilla.mozilla.org/show_bug.cgi?id=1455147
>>
> [6] https://www.camerfirma.com/camerfirma/acreditaciones/
>>
> [7]
>> http://docs.camerfirma.com/publico/DocumentosWeb/politicas/CPS_3.3.1_EN.pdf
>>
> [8]
>> https://crt.sh/?sha256=06a57d1cd5879fba2135610dd8d725cc268d2a6de8a463d424c4b9da89848696&opt=mozilladisclosure
>
> [9]
>> https://crt.sh/?sha256=1defd59846cc2049ba1f1a74d3a8329d1357a2d47c1e1b0c15c27a8c60295455&opt=mozilladisclosure
>>
> [10] https://crt.sh/?cablint=319&iCAID=1778&minNotBefore=2017-01-01
>
>
>
>
>
>
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