On Thu, Dec 20, 2018 at 10:34:21PM +0000, Jeremy Rowley via dev-security-policy 
wrote:
> Here’s the first of the companies. Figured I’d do one and see if it has the 
> information you want. 
> 
> https://bugzilla.mozilla.org/show_bug.cgi?id=1515788

Complete side-note: when the customer said you couldn't identify them by
name, did they know you were going to be linking to a whole pile of
certificates with their organizationName in them?  <grin>

> I think this answers all of your questions (except Ryan’s question about
> remediation).  Could you let me know if more detail is required or if
> you’d like additional info included?

The question that comes to my mind most of all is tangentially related to
Ryan's question around long-term remediation, but I'll ask it anyway as it's
at least somewhat independent.

You state in the bug you linked that "[The certificates] can't be replaced
before [April 30, 2019] because of the code freeze and the risk of an
outage".  That is an absolute statement, which I take to mean that there is
*no* possibility of certificates being replaced in the freeze period (Oct
15-Feb 1).

So, my question is: what would this organization do if they had suffered a
key compromise (to take one possible reason for immediate revocation, which
happens to be forefront in my mind) on Oct 16?  Would this organization
continue to use a certificate which uses a known-compromised key until
possibly as late as April 30 -- which, if my counting-on-fingers is correct,
is approximately six and a half months?  Would DigiCert consider not
revoking the certificate with a compromised key for that long, if the
customer asked them to?  Would DigiCert expect trust stores to bless that
decision?

If the answer to the above questions is "no, of course not!" (as I would
sincerely hope they would be), then your absolute statement that the
certificates "*can't* be replaced" should probably read something more like
"the organization would prefer not to replace the certificates before then,
because it is a lot of work and entails some degree of risk".  Which takes
us back to the calculus of options:

1. DigiCert revokes, organization changes domain names and certs: the
   organization does lots of work, and takes the risk of Things Going Very
   Wrong because of domain name and cert changes.

2. DigiCert revokes, organization switches to 30 day certs: the organization
   does lots of work, and takes the risk of Things Going Very Wrong because
of cert changes.

3. DigiCert revokes, organization doesn't swap certs: the organization does
   lots of work, and takes the risk of Things Going Very Wrong because of
   revocation checking.

4. DigiCert doesn't revoke, on its own behest: the organization does no
   work, takes no risk, while DigiCert takes the risk of consequences from
   trust stores of failing to follow the BRs.

5. DigiCert doesn't revoke, trust stores bless this decision: the
   organization does no work and takes no risk, DigiCert takes no risk,
   while trust stores take the risk that CAs' future behaviour is influenced
   by the appearance that deliberately failing to adhere to the BRs carries
   little-to-no consequences.

Given that the entities which made the decisions which led to the current
situation are DigiCert (for allowing issuance of invalid certificates) and
this organization (which failed to heed their subscriber agreement and
decided to build an infrastructure which cannot be adjusted on the timeframe
required under their subscriber agreement), can you explain why it is
reasonable for the trust stores -- which appear to have done nothing
inappropriate to cause the current state of affairs -- to be the ones taking
on *any* of the risk here?

Please don't think that I'm not sympathetic to the situation this "Major
Pharmacy Benefits Manager" and DigiCert are in -- my day job is keeping
production systems up and running, and the idea of having to make fast
changes isn't one I enjoy.  Running a commercial entity is never made any
easier when you have to cause problems for your customers.  SC12 is not the
phase-out plan *I* would have chosen, were I Benevolent Dictator of the
Internet.  However, now that it is the plan which has been put in place,
following the rules of the game trust stores and CAs have agreed to play by,
I find it disconcerting that DigiCert and Organization One want to shift the
risk for their decisions onto trust stores.  What is the *benefit* to trust
stores in taking on that risk, to the undeniable benefit to DigiCert and
Organization One?

Perhaps, at the end of the day, *that* is the real question to be answered.

- Matt

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