Any update behind the scenes about this issue? I've noticed that the soft limit 
to fill an Incident Report expired more than a week ago, and I'm starting to be 
a bit worried that some of the evidence in the CT logs might disappear if the 
investigation is not completed before December 6th, the earliest expiration 
date among the affected certificates.

Guillaume Fortin-Debigaré
________________________________
From: please please <pleaseiwantt...@hotmail.com>
Sent: September 17, 2018 23:39
To: Wayne Thayer
Cc: MDSP
Subject: Re: Violation report - Comodo CA certificates revocation delays

Good to know, and thank you very much for following up on this!

Small update by the way: I finally received a reply from Comodo CA confirming 
their 2nd wave of revocations a few hours ago, on September 17 at 16:55 UTC to 
be exact. Strangely, it was in response to an email where I informed them that 
I had already noticed they fully completed my revocation request. I don't think 
it's a relevant detail but I wanted to mention it to avoid any potential 
confusion.

Guillaume Fortin-Debigaré

________________________________
From: Wayne Thayer <wtha...@mozilla.com>
Sent: September 17, 2018 20:09
To: pleaseiwantt...@hotmail.com
Cc: MDSP
Subject: Re: Violation report - Comodo CA certificates revocation delays

I have created a bug and requested a response from Comodo: 
https://bugzilla.mozilla.org/show_bug.cgi?id=1492006

As noted, there are no specific requirements regarding how CAs validate 
revocation requests in the BRs. Every CA may do this however they choose, so I 
don't believe there is any action required in regard to DigiCert's response to 
their problem report.

- Wayne

On Sun, Sep 16, 2018 at 8:30 PM please please via dev-security-policy 
<dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>>
 wrote:
Hello, I am the domain owner of debigare.com<http://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<http://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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