Dear Ryan,

A fair and transparent public discussion requires full disclosure of each 
participant's motivations and ultimate agenda.  Whether in CABForum, or 
Mozilla-dev-security-policy, I represent the viewpoints of my employer 
DarkMatter and passionately believe in our unflagging efforts to provide the 
citizens, residents and visitors to the United Arab Emirates with the same 
internet security and privacy protections that are taken for granted in other 
parts of the world.

On Wednesday, March 6, 2019 7:51 PM, Ryan Sleevi wrote:
>  (Writing in a personal capacity)

Until such time as we have been formally advised by your employer (Google), 
that you no longer represent their views in CABForum, or in this 
Mozilla-dev-security-policy forum, we will proceed on the basis that all of 
your statements are the official viewpoint of your employer (Google).

>   I highlight this, because given the inherently global nature of the
>   Internet,  there is no technical need to work with local CAs, and,
>   with a well-run root store,  all CAs provide an equivalent level of
>   protection and security, which rests in the domain authorization

We reject your paternalistic view that there is no technical need for a local 
United Arab Emirates CA.  Our own research has determined that approximately 
68% of the websites in the United Arab Emirates are not adequately protected 
for HTTPS traffic (double the global average).  If those incumbent CA 
monopolies that you champion were doing such a great job globally - why such a 
stark difference?

We are of the view that CA monopolies are inherently bad for the internet in 
that they unfairly exploit market power. The result is  a fundamental right to 
Internet security and privacy being deliberately priced out of reach for a 
significant population of the world.  We ask you, what can be more an 
anti-competitive monopoly than  a "well run store" (read Google/Mozilla) that 
does not take into consideration that sovereign nations have the fundamental 
right to provide digital services to their own citizens, utilizing their own 
national root, without being held hostage by a provider situated in another 
nation.  You should note that DarkMatter's request is also for the inclusion of 
UAE's national root.

>    DarkMatter response to the serial number issue has demonstrated
>    that DarkMatter did not do the expected due diligence to investigate
>    and understand the issue.

Your statement as Google's representative is quite disingenuous and 
self-serving.   As a new member of the CABForum, we were not privy to the 
discussions for Ballot 164, and have interpreted the Baseline Requirements as 
they were written.   We have made the necessary incident report and 
corrections. [1]  We note that your own employer, Google, also discovered that 
it had the same entropy non-compliance with its serial numbers (as a result of 
the DarkMatter discussions highlighting it to them), and we presume that 
hundreds of thousands of certificate's would be affected globally (in 
comparison to the less than 300 impacted DarkMatter certificates).[2]  Clearly 
the risk to users is larger in the Google case.  Are you also going to accuse 
your employer (Google) as not having undertaken "the expected due diligence to 
investigate and understand the issue" that you demand from DarkMatter, and call 
for the same sanctions against Google that you wish to impose on DarkMatter?

Does the Mozilla foundation stand by this double-standard because Google is one 
of its significant donors, and its default search engine? Reports indicate that 
in 2014, 90% of Mozilla's royalties revenue was derived from its contract with 
Google. We understand that the relationship persists today. [3] Transparency in 
a public discussion requires full disclosure and transparency from all - not 
just DarkMatter.

>    You have highlighted that you believe such articles are misleading,
>     but there  are a number of unresponded questions to past replies
>     that seek to better understand.

I am glad that you brought this up directly with me - and in this public 
discussion.  Ryan, you have been one of the individuals who have been 
persistent in spreading this false narrative - as far back as February 2018 - 
during our initial submission to CABForum.  We have duly noted and have been 
aware of your persistent attempts to interfere with our contractual relations.  
Your employer should know that we have had to expend considerable effort to 
defend against your back-room politicking, and defamatory innuendos, about the 
nature of our business.

For the record, there are simply two (2) articles, which cite defamatory and 
categorically false sources, making utterly baseless allegations about 
DarkMatter's purpose and mission.  These two narratives have been recycled 
repeatedly by journalists seeking a lurid and sensationalist myth-making angle 
on our purpose and mission.  Repeating a lie ad-nauseam does not make it true.  
CA representatives (including the Mozilla representatives who have chosen to 
pre-judge DarkMatter using the same media sources ) do a great disservice to 
the idea of "trust" - when they persist in a concerted effort to accelerate 
this false narrative about DarkMatter, a commercial CA business head-quartered 
in the United Arab Emirates.

Read my statement carefully:  there are no ambiguities or loopholes in our 
categorical denials of any false claim made about DarkMatter in these 
misleading articles.  These claims are baseless and have nothing to do with 
DarkMatter.

It is very clear to us that your paternalistic dismissal of the need for 
regional or "local CAs" seems to indicate a hidden motivation: less CA's 
offering competitive services in the marketplace.  Our view is clear and 
unambiguous: when CA's, or Root Store operators use their participation in the 
these process -  in a manner that is intended to arbitrarily and without any 
valid proof, restrict or impede the inclusion of DarkMatter certificates, they 
are colluding to create an economic environment that is contrary to anti-trust 
laws.


Benjamin Gabriel
General Counsel
Dark Matter Group



Benjamin Gabriel | General Counsel & SVP Legal
Tel: +971 2 417 1417 | Mob: +971 55 260 7410
benjamin.gabr...@darkmatter.ae

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