What concerns me overall in this discussion is the fact that some CAs
thought it was completely acceptable to barely scrape through to meet the
most basic minimum of requirements. I hope these CAs have a better security
posture and are not operating at the minimum.

Thank you,

Burton

On Sat, Mar 9, 2019 at 8:24 PM Ryan Sleevi via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> On Sat, Mar 9, 2019 at 2:49 PM Dimitris Zacharopoulos <ji...@it.auth.gr>
> wrote:
>
> > The question I'm having trouble answering, and I would appreciate if this
> > was answered by the Mozilla CA Certificate Policy Module Owner, is
> >
> > "does Mozilla treat this finding as a violation of the current language
> of
> > section 7.1 of the CA/B Forum Baseline Requirements"?
> >
>
> I think for Mozilla, this is best answered by Kathleen, Wayne, the Mozilla
> CA Policy Peers, and which I am not.
>
> On behalf of Google and the Chrome Root Authority Program, and consistent
> with past discussion in the CA/Browser Forum regarding expectations [1], we
> do view this as a violation of the Baseline Requirements. As such, the
> providing of incident reports, and the engagement with public discussion of
> them, represents the most transparent and acceptable course of action.
>
> Historically, we have found that the concerns around incident reporting
> have been best addressed through a single, unified, and transparent
> engagement in the community. Much as ct-pol...@chromium.org has happily
> and
> intentionally supported collaboration from counterparts at Mozilla and
> Apple, Mozilla has historically graciously allowed  for the unified
> discussion on this mailing list, and the use of their bugtracker for the
> purpose of engaging publicly and transparently on incident reports that
> affect the Web PKI. Should Mozilla have a different interpretation of the
> Baseline Requirements’ expectations on this, we’d seek guidance as to
> whether or not the bug tracker and mailing list continue to represent the
> best place for discussion of this specific issue, although note that
> historically, this has been the case.
>
> This should make it clear that CAs which extracted 64 bits of entropy as an
> input to an algorithm that then set the sign bit to positive and
> potentially decreasing the entropy to 63 bits, as opposed to
> unconditionally guaranteeing that there was a positive integer with _at
> least_ 64 bits of entropy, are non-compliant with the BRs and program
> expectations, and should file incident reports and include such disclosures
> in their reporting by and assertions to auditors.
>
> [1]
> https://cabforum.org/pipermail/public/2016-April/007245.html
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