Hi,

In April and May of this year, I attempted to change the address listed in Dun 
& Bradstreet of my (Kentucky-incorporated) company "Stripe, Inc" to an address 
in Toledo, Ohio that did not exist (185 Berry Street Toledo Ohio). I was 
wondering the extent of validation Dun & Bradstreet would do on the data.

To my surprise, they accepted my change request a couple days later. This is 
concerning, of course, because D&B is a QIIS backing most EV certificate 
requests in the United States. 

After this worked, I realized this was probably worth exploring more, so I took 
my "Cloudflare, Inc" company (also incorporated in Kentucky) and requested that 
Dun & Bradstreet change its address to "102 Townsend St San Francisco CA". You 
might notice that this is the same address as the real Cloudflare, but with the 
street number incremented by one.

D&B accepted that change request as well. This meant I controlled a DUNS number 
that would resolve to a very similar address to CF, with my phone number on it.

I ordered two EV certificates from Comodo (order #s 136665865 and 141269115) 
with these fake DUNS numbers. I successfully completed the validation and 
callback process for the Cloudflare order, and Comodo was about to issue the 
certificate, but both of my orders were silently deleted before they were about 
to be issued.

Comodo would not give me any information about why they (silently) rejected my 
orders, but Dun & Bradstreet banned my account shortly after, so it is safe to 
say they reported me after they realized something went wrong.

I think this is a strong indictment of D&B as a QIIS. The definition of a QIIS, 
in my opinion, is incredibly lax, but "which is generally recognized as a 
dependable source of such information" is hard to meet here.

I am also, frankly, annoyed that Comodo seems to have silently discovered that 
D&B was unreliable and then ignored it without reporting it further. I myself 
have been meaning to send this for a while, given I did this in May, but 
various things have made it difficult for me to find the time.

Let me know if I can provide any further information.
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