On Thu, Mar 07, 2019 at 08:47:46PM -0600, Matthew Hardeman via 
dev-security-policy wrote:
> On Thu, Mar 7, 2019 at 8:29 PM Ryan Sleevi via dev-security-policy <
> dev-security-policy@lists.mozilla.org> wrote:
> > Past analysis and discussion have shown the interpretation is hardly
> > specific to a single CA. It was a problem quite literally publicly
> > discussed during the drafting and wording of the ballot. References were
> > provided to those discussions. Have you gone and reviewed them? It might be
> > helpful to do so, before making false statements that mislead.
> 
> "Effective September 30, 2016, CAs SHALL generate non-sequential
> Certificate serial numbers greater than zero (0) containing at least 64
> bits of output from a CSPRNG. "  [1]
> 
> Irrespective of the discussion underlying the modifications of the BRs to
> incorporate this rule, there are numerous respondent CAs of varying
> operational vintage, varying size, and varying organizational complexity.

Yes, there are, and they all have a huge burden of trust placed on them. 

> The history underlying a rule should not be necessary to implement and
> faithfully obey a rule.

I absolutely agree with this.  Thankfully, there is no requirement to
understand the history behind the changes under discussion in order to
correctly implement it.

> Rather than have us theorize as to why non-compliance with this rule seems
> to be so widespread, even by a number of organizations which have more
> typically adhered to industry best practices, would you be willing to posit
> a plausible scenario for why all of this non-compliance has gone on for so
> long and by so many across so many certificates?

Because, like so many other things that go on for a long time before they're
discovered, nobody took a look.

> Additionally, assuming a large CA with millions of issued certificates
> using an actual 64-bit random serial number...  Should the CA also do an
> exhaustive issued-serial-number search to ensure that the to-be-signed
> serial number  is not off-by-one in either direction from a previously
> issued certificate serial number?  However implausible, if it occurred,
> this would indeed result in having participated in the issuance of 2
> certificates with sequential serial numbers.

Having sequential serial numbers is not problematic.  Having *predictable*
serial numbers is problematic.

- Matt

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