I appreciate the ground work Fabio put into this thus far, and want to
see further discussion on it.

I think the safest way to quantity and frame the discussion is asking if
a CA (or subCA) has a vested interest in surveillance, other business
interest, or government ties which would put a CA to be more likely to
abuse the trust, or has a history of business practices related to
surveillance or practices against the public interest in regards to WebPKI.

I recognize the points Scott brought up, but trust is always a
subjective thing. As previously pointed out, Mozilla has always retained
the ability to choose what to include or disallow based on community
input, and this entire thread shows there is a lot of community input here.

The problem with auditing in general is its only going to catch
information that is logged and archived in a corporation. It's an
assurance step but in and of itself is not enough to establish trust; it
not uncommon for misissues and other issues to be noted by the community
from information in the wild
Michael

On 7/10/19 3:59 AM, fabio.pietrosanti--- via dev-security-policy wrote:
> I understand the Nadim points, there's a lot of subjective biased "popular 
> judgement".
> 
> While from a security standpoint perspective "better safe than sorry" is a 
> good statement, from a rights and fairness perspective that's a very bad.
> 
> So further conversation is needed.
> 
> Following DarkMatter removal i would love to bring to the attention of 
> Mozilla the removal of a list of Companies that does as a main business other 
> stuff, but also does offensive security and surveillance with public 
> "credible evidences" .
> 
> I've analysed Intermediate CA list where DarkMatter is here 
> https://ccadb-public.secure.force.com/mozilla/PublicAllIntermediateCerts .
> 
> In this list is possible to find the following company operating against 
> "people's safety" and there's "credible evidences" they are doing so:
> 
> 
> * Saudi Telecom Company
> 
> This company is publicly known to ask to surveil and intercept people as per 
> "credible evidences" on:
> https://moxie.org/blog/saudi-surveillance/
> https://citizenlab.ca/2014/06/backdoor-hacking-teams-tradecraft-android-implant/
> 
> 
> * German Rohde & Schwarz
> 
> This company do produce, install and support surveillance systems for 
> intelligence agencies in Regimes such as Turkmenistan:
> https://www.rferl.org/a/german-tech-firm-s-turkmen-ties-trigger-surveillance-concerns/29759911.html
> 
> They sell solutions to intelligence agencies such as IMSI Catchers and 
> massive internet surveillance tools:
> https://www.rohde-schwarz.com/en/solutions/aerospace-defense-security/overview/aerospace-defense-overview_229832.html
> 
> 
> * US "Computer Sciences Corporation"
> 
> The CSC is a US Intelligence and Defense Contractors that does CNE (Computer 
> Network Exploitation) like the WikiLeaks ICWatch show out
> 
> Read the profile of a former employee of CSC, doing CNE like Snowden was 
> doing:
> https://icwatch.wikileaks.org/docs/rLynnette-Jackson932c7871cb1e83f3%3Fsp=0ComputerSciencesCorporationCyberSecurityAnalystSystemsEngineerRemoteSystemAdministrator2008-09-01icwatch_indeed
> 
> Additionally from their wikipedia they acknowledge working for US Intel:
> https://en.wikipedia.org/wiki/Computer_Sciences_Corporation
> 
> CSC provided services to the United States Department of Defense,[23] law 
> enforcement and intelligence agencies (FBI,[24] CIA, Homeland Security[23]), 
> aeronautics and aerospace agencies (NASA). In 2012, U.S. federal contracts 
> accounted for 36% of CSC total revenue.[25]
> 
> 
> * Australia's Attorney-General's Department
> 
> The Australia's Attorney-General's Department is a government agencies that 
> wants to permit the Australian Security Intelligence Organisation (ASIO) to 
> hack IT systems belonging to non-involved, non-targeted parties.
> 
> It operate against people safety and there's credible evidence of their 
> behaviour in supporting ASIO to hack people, so they are very likely to abuse 
> their intermediate CA:
> http://www.h-online.com/security/news/item/Australian-secret-services-to-get-licence-to-hack-1784139.html
> 
> 
> * US "National Geospatial-Intelligence Agency" https://www.nga.mil
> 
> The NGA is a US Military Intelligence Agency, equivalent to NSA, but 
> operating on space GEOINT and SIGINT in serving intelligence and defense US 
> agencies.
> 
> NGA is the Space partner of NSA:
> https://www.nsa.gov/news-features/press-room/Article/1635467/joint-document-highlights-nga-and-nsa-collaboration/
> 
> I think that no-one would object to shutdown an NSA operated Intermediate CA, 
> i am wondering if Mozilla would consider this removal.
> 
> 
> Said that, given the approach that has been following with DarkMatter about 
> "credible evidence" and "people safety" principles, i would strongly argue 
> that Mozilla should take action against the subject previously documented.
> 
> I will open a thread on those newsgroup for each of those company to 
> understand what's the due process and how it will compare to this.
> 
> Fabio Pietrosanti (naif)
> 
> Il giorno martedì 9 luglio 2019 18:19:36 UTC+2, Nadim Kobeissi ha scritto:
>> Dear Wayne,
>>
>> I fully respect Mozilla's mission and I fully believe that everyone here is
>> acting in good faith.
>>
>> That said, I must, in my capacity as a private individual, decry what I
>> perceive as a dangerous shortsightedness and lack of intellectual rigor
>> underlying your decision. I do this as someone with a keen interest in
>> Internet freedom issues and not as someone who is in any way partisan in
>> this debate: I don't care for DarkMatter as a company in any way whatsoever
>> and have no relationship with anyone there.
>>
>> I sense enough urgency in my concerns to pause my work schedule today and
>> respond to this email. I will do my best to illustrate why I sense danger
>> in your decision. Essentially there are three specific points I take issue
>> with:
>>
>> -----------------
>> 1: Waving aside demands for objective criteria.
>> -----------------
>> You say that "if we rigidly applied our existing criteria, we would deny
>> most inclusion requests." Far from being an excuse to put more weight (or
>> in this case, perhaps almost all weight) on subjective decision making,
>> this should be a rallying cry for Mozilla to investigate why it is that an
>> objective and democratic decision-making process is failing, and what can
>> be done to make it work better. Waving aside objective procedures as
>> "checklists" dismisses a core procedural element of how such critical
>> decisions should be made in the future and is explicitly undemocratic and
>> therefore dangerous.
>>
>> -----------------
>> 2: Calling allegations "credible" and "extensively sourced" with almost no
>> basis whatsoever.
>> -----------------
>> You cite four articles: two are from the Intercept, one is from Reuters and
>> one is from the New York Times. You claim that the fact that they are years
>> apart bolsters their credibility; why is this the case? In fact, these
>> articles all parrot almost exactly the same story, with some minor
>> additions, updates and modifications. They all almost read like the same
>> article, despite their temporal distribution. Furthermore, the notion that
>> the articles are "extensively sourced" is simply incorrect: all of the
>> articles are based on anonymous sources and none of them provide a shred of
>> evidence, which is why we are in this debate to begin with (or so I've been
>> thinking).
>>
>> It should also be noted that both The Intercept and the New York Times have
>> published misleading and incorrect information many times in their history.
>> The Intercept in particular has a very spotty credibility record.
>>
>> It is also is not difficult to theorize how a politically trendy topic
>> (cyberattacks) against the world's most easy-to-villainize company (an
>> Arabic offensive cybersecurity company operating within a true monarchic
>> state) would be appealing to American journalists. This sort of thing isn't
>> new, and American "digital rights" groups have previously linked malicious
>> cyberattacks to Middle Eastern countries without providing something that
>> is even close to the same standard of evidence that they almost always
>> provide when naming American or European actors.
>>
>> Is is indeed unfortunate that this issue was dealt with in a single
>> paragraph: I would have expected it to be the brunt of the email given its
>> importance, and it is impossible to qualify that reporting as "credible"
>> and "extensively sourced" so summarily.
>>
>> -----------------
>> 3: Culminating in an argument that simply boils down to "the people's
>> safety", a trope that is often overused and that leads to undemocratic
>> behavior.
>> -----------------
>>
>> We don't know if DarkMatter is an evil spying empire that doesn't care
>> about the rights and dignity of private citizens or not. We don't know if
>> they're setting up shell companies to mislead Mozilla's CA vetting
>> procedures or not. In fact, it's been months where no new information has
>> arisen and I would like to repeat that I do not _at all_ discount the
>> possibility that all of the allegations may turn out to be completely true.
>>
>> But instead of making effort towards resolving this uncertainty, or, in
>> case that's not possible, create procedures to deal with it, we see it
>> being wielded in order to increase the subjectivity of the decision making
>> that gatekeeps some of the most fundamental issues of Internet security and
>> to legitimize shoddy thinking.
>>
>> Individually, your apparent decision against DarkMatter doesn't bother me.
>> It is the decision making process itself however that risks setting a
>> dangerous precedent that is already taking shape in other parts of the tech
>> community, where major decisions are predicated on gut feeling and notions
>> of safety that are almost by design impossible to elucidate, and where
>> much-needed objectivity, vetting and reasoned behavior is relegated to
>> one-shot paragraphs that barely come with an apology.
>>
>> In conclusion: perhaps it is exactly because DarkMatter are so incredibly
>> easy to demonize that we are so temporarily blind to an infinitely more
>> dangerous and terrifying lapse of judgement: one that may come from much
>> closer to home. I don't mind if DarkMatter loses out here, but I urge you
>> to self-reflect critically on what this decision may constitute in terms of
>> a future trend.
>>
>> Presented with the utmost respect and good faith,
>>
>> Yours sincerely,
>>
>> Nadim Kobeissi
>> Symbolic Software • https://symbolic.software
>> Sent from office
>>
>>
>> On Tue, Jul 9, 2019 at 5:31 PM Wayne Thayer <wtha...@mozilla.com> wrote:
>>
>>> I would like to thank everyone for their constructive input on this
>>> difficult issue. I would also like to thank DarkMatter representatives for
>>> participating in the open, public discussion. I feel that the discussion
>>> has now, after more than 4 months, run its course.
>>>
>>> The question that I originally presented [1] to this community was about
>>> distrusting DarkMatter’s current intermediate CA certificates (6 total)
>>> based on credible evidence of spying activities by the company. While a
>>> decision to revoke trust in these intermediates would likely result in a
>>> denial of DarkMatter’s root inclusion request [2], the public discussion
>>> for that request has not yet begun. A decision not to revoke these
>>> intermediates does not necessarily mean that the inclusion request will be
>>> approved.
>>>
>>> Some of this discussion has revolved around compliance issues, the most
>>> prominent one being the serial number entropy violations discovered by
>>> Corey Bonnell. While these issues would certainly be a consideration when
>>> evaluating a root inclusion request, they are not sufficient to have
>>> triggered an investigation aimed at revoking trust in the DarkMatter
>>> intermediates or QuoVadis roots. Therefore, they are not relevant to the
>>> question at hand.
>>>
>>> Much of the discussion has been about the desire for inclusion and distrust
>>> decisions to be made based on objective criteria that must be satisfied.
>>> However, if we rigidly applied our existing criteria, we would deny most
>>> inclusion requests. As I stated earlier in this thread, every distrust
>>> decision has a substantial element of subjectivity. One can argue that
>>> we’re discussing a different kind of subjectivity here, but it still
>>> amounts to a decision being made based on a collective assessment of all
>>> the information at hand rather than a checklist.
>>>
>>> Some, including DarkMatter representatives [3], have declared the need to
>>> examine and consider the benefits of having DarkMatter as a trusted CA.
>>> However, last year we changed our policy to replace the weighing of
>>> benefits and risks with “based on the risks of such inclusion to typical
>>> users of our products.” [4]
>>>
>>> Perhaps the most controversial element in this discussion has been the
>>> consideration of “credible evidence”. The first component is the inherent
>>> uncertainty over what is “credible”, especially in this day and age. While
>>> it has been pointed out that respected news organizations are not beyond
>>> reproach [5], having four independent articles [6][7][8][9] from reputable
>>> sources published years apart does provide some indication that the
>>> allegations are credible. These articles are also extensively sourced.
>>>
>>> If we assume for a second that these allegations are true, then there is
>>> still a sincere debate over what role they should play in our decision to
>>> trust DarkMatter as a CA. The argument for considering these allegations is
>>> akin to the saying “where there’s smoke there’s fire”, while the argument
>>> against can be described as “innocent until proven guilty”.
>>>
>>> DarkMatter has argued [3] that their CA business has always been operated
>>> independently and as a separate legal entity from their security business.
>>> Furthermore, DarkMatter states that once a rebranding effort is completed,
>>> “the DarkMatter CA subsidiary will be completely and wholly separate from
>>> the DarkMatter Group of companies in their entirety.” However, in the same
>>> message, DarkMatter states that “Al Bannai is the sole beneficial
>>> shareholder of the DarkMatter Group.” and leaves us to assume that Mr. Al
>>> Bannai would remain the sole owner of the CA business. More recently,
>>> DarkMatter announced that they are transitioning all aspects of the
>>> business to DigitalTrust and confirmed that Al Bannai controls this entity.
>>> This ownership structure does not assure me that these companies have the
>>> ability to operate independently, regardless of their names and legal
>>> structure.
>>>
>>> Mozilla’s principles should be at the heart of this decision. “The Mozilla
>>> Manifesto [10] states:
>>>
>>> Individuals’ security and privacy on the internet are fundamental and must
>>> not be treated as optional.”
>>>
>>> And our Root Store policy states: “We will determine which CA certificates
>>> are included in Mozilla's root program based on the risks of such inclusion
>>> to typical users of our products.”
>>>
>>> In other words, our foremost responsibility is to protect individuals who
>>> rely on Mozilla products.  I believe this framing strongly supports a
>>> decision to revoke trust in DarkMatter’s intermediate certificates. While
>>> there are solid arguments on both sides of this decision, it is reasonable
>>> to conclude that continuing to place trust in DarkMatter is a significant
>>> risk to our users. I will be opening a bug requesting the distrust of
>>> DarkMatter’s subordinate CAs pending Kathleen’s concurrence. I will also
>>> recommend denial of the pending inclusion request, and any new requests
>>> from DigitalTrust.
>>>
>>> In the past, we’ve seen CAs attempt to make an end run around adverse trust
>>> decisions - through an acquisition, a shell company, etc. We will treat any
>>> such attempt as a violation of this decision and act accordingly. Mozilla
>>> does welcome DigitalTrust as a “managed” subordinate CA under the oversight
>>> of an existing trusted CA that retains control of domain validation and the
>>> private keys.
>>>
>>> This discussion has highlighted an opportunity to improve our review of new
>>> externally-operated subordinate CAs [11]. This issue [12] is part of the
>>> current policy update discussions.
>>>
>>> Wayne
>>>
>>> [1]
>>>
>>> https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/YiybcXciBQAJ
>>> [2] https://bugzilla.mozilla.org/show_bug.cgi?id=1427262
>>> [3]
>>>
>>> https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/mJ0EV2eoCgAJ
>>> [4]
>>>
>>> https://groups.google.com/d/msg/mozilla.dev.security.policy/58F6FgeGOz8/Zzb-r76wBQAJ
>>> [5]
>>>
>>> https://www.washingtonpost.com/blogs/erik-wemple/wp/2018/11/27/bloomberg-is-still-reporting-on-challenged-story-regarding-china-hardware-hack/
>>> [6]
>>>
>>> https://theintercept.com/2016/10/24/darkmatter-united-arab-emirates-spies-for-hire/
>>> [7] https://www.reuters.com/investigates/special-report/usa-spying-raven/
>>> [8]
>>>
>>> https://www.nytimes.com/2019/03/21/us/politics/government-hackers-nso-darkmatter.html
>>> [9] https://theintercept.com/2019/06/12/darkmatter-uae-hack-intercept/
>>> [10] https://www.mozilla.org/en-US/about/manifesto/
>>> [11]
>>>
>>> https://ccadb-public.secure.force.com/mozilla/IntermediateCertsSeparateAudits
>>> [12] https://github.com/mozilla/pkipolicy/issues/169
>>>
> 
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