I just poked Comodo in the bug -
https://bugzilla.mozilla.org/show_bug.cgi?id=1492006

CT Logs are designed such that certificates cannot be removed from them.
The evidence will not disappear once the certificates expire.

On Wed, Oct 10, 2018 at 5:26 PM please please <pleaseiwantt...@hotmail.com>
wrote:

> 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> wrote:
>
> 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
> _______________________________________________
> dev-security-policy mailing list
> dev-security-policy@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy
>
>
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