Hi,

Today I noticed that Firefox shows "verified by <subCA subjectCompanyName>"
when you hover over the lock in the URL box; and that on this website [0]
that was Cloudflare, Inc. This was a suprise to me; as I had not before
heard about Cloudflare operating a CA. After some digging, I found that the
subCA that signed the certificate was  branded with Cloudflare Inc. [1] and
is actually operated by DigiCert, and (according to crt.sh) would be
subject to the DigiCert CPS (which seems to be [2]).

However; I could not find any reference to Cloudflare in the DigiCert CPS.
And; seeing that DigiCert's CPS disallows delegation of IP / domain
validation; this would mean that at least some part of the validation is
done by DigiCert; not Cloudflare -- I'd even argue that the most important
part of the validation was done by DigiCert -- organization information is
of limited value in TLS connections.

This puts up the following questions:

Should this information be displayed as such?
In my opinion, it the current UI (both the hover and the second screen of
the 'site security info' popup) misinforms the user in believing that (in
this case) Cloudflare has validated that this certificate was issued to the
right web server. This is not completely incorrect; as Cloudflare could
have provided the organization validation of the OV certificate, but it did
provide me with an incorrect impression until I had fully worked out the CA
chain involved.

Next, should a subCA be allowed to be branded under another company's name
while (presumably) still under full control of the parent CA?
Specifically; should a CA be allowed to sign an unconstrained CA
certificate for which they know that they will be the ones operating it;
and that the subject:organizationName donor is involved effectively only in
name; not in function?
If that intermediate CA is the Issuing CA, then that would indicate that
this second party that donated the name did meaningfully validate and sign
the leaf certificate; which is incorrect and misleading.
I know that a Certificate Authority may be the delegated party of a
subscriber and may thus sign (CA) certificates with the subscriber as
subject; but I think that it is very much misleading the relying party; at
which I'd like to note that when "[t]he Issuing CA determines that any of
the information appearing in the [Subordinate CA] Certificate is inaccurate
or misleading" the Subordinate CA Certificate must be revoked within 7 days
(BR s4.9.1.2 (6)).


Kind regards,

Matthias van de Meent


[0] https://discord.com
[1] Cloudflare Inc ECC CA-3: https://crt.sh/?caid=157939,
Cloudflare Inc RSA CA-2:https://crt.sh/?caid=157939
[2]
https://www.digicert.com/content/dam/digicert/pdfs/legal/digicert-cps-v5-9.pdf,
repository: https://www.digicert.com/legal-repository

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