Here are the results of my triage:

*CA* *Bugzilla* *Status*
HARICA https://bugzilla.mozilla.org/show_bug.cgi?id=1945389 Too new
Entrust https://bugzilla.mozilla.org/show_bug.cgi?id=1943528 Too new
GlobalSign https://bugzilla.mozilla.org/show_bug.cgi?id=1942879 Set to close
GoDaddy https://bugzilla.mozilla.org/show_bug.cgi?id=1942877 Next update is
April 1
KIR https://bugzilla.mozilla.org/show_bug.cgi?id=1922572 Next update is
March 7
eMudhra https://bugzilla.mozilla.org/show_bug.cgi?id=1916478
<https://bugzilla.mozilla.org/show_bug.cgi?id=1916478#c10> Posted comment
DigiCert https://bugzilla.mozilla.org/show_bug.cgi?id=1910805 Active
Discussion
Chunghwa Telecom https://bugzilla.mozilla.org/show_bug.cgi?id=1903066 Set
to close
Entrust https://bugzilla.mozilla.org/show_bug.cgi?id=1898848 Closure
Summary requested
Netlock https://bugzilla.mozilla.org/show_bug.cgi?id=1891331
<https://bugzilla.mozilla.org/show_bug.cgi?id=1891331#c32> Comment posted
GDCA https://bugzilla.mozilla.org/show_bug.cgi?id=1889062 New Action Items
needed
CFCA https://bugzilla.mozilla.org/show_bug.cgi?id=1888882 New Action Items
needed
Hong Kong Post https://bugzilla.mozilla.org/show_bug.cgi?id=1887888 New
Action Items needed
Microsec https://bugzilla.mozilla.org/show_bug.cgi?id=1887110 Closure
Summary requested
Hong Kong Post https://bugzilla.mozilla.org/show_bug.cgi?id=1886665 New
Action Items needed
Entrust https://bugzilla.mozilla.org/show_bug.cgi?id=1886532 Closure
Summary requested
Viking Cloud https://bugzilla.mozilla.org/show_bug.cgi?id=1885568 Closure
Summary requested
Buypass https://bugzilla.mozilla.org/show_bug.cgi?id=1872738 Set to close
Ben

On Mon, Feb 10, 2025 at 12:22 PM Tim Callan <[email protected]> wrote:

> I appreciate that this matter already has been discussed and accept
> Jeremy’s explanation and retraction, and I have no interest in reopening
> that conversation.  Nonetheless, based on this thread it feels to me that
> we would be wise to articulate our motivations.
>
>
>
> About five years ago, Sectigo was in a bad place as a public CA. The
> company’s commitment to quality of execution, accurate issuance,
> responsibility to the WebPKI, and continuous improvement was abysmal. This
> manifested itself in a series of severe errors that should not have
> occurred accompanied by terrible management of the resulting Bugzilla
> incidents.
>
>
>
> I sincerely believe that had Sectigo continued down that path, our roots
> would be distrusted today
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1714628#c11>.  Fortunately,
> a few thought leaders inside the company had this epiphany, made their
> voices heard, and ultimately convinced those around them.  This led to
> clear policy changes inside Sectigo and began a process that in the long
> term required widespread technical, cultural, procedural, and leadership
> reform.  We forged new (for us at least) philosophies about information,
> quality control, operational efficiency, certificate morphology, policy
> governance, internal communication, external communication, automation, and
> the proper role of humans in our processes. There is pretty much no aspect
> of our public CA operation that we did not scrutinize and renovate in the
> past five years. While we don’t think we’re perfect by a long shot, we know
> beyond doubt that we have come a great distance.
>
>
>
> It's been a lengthy, hard journey that has required deep thinking,
> unflinching self-examination, guts, persistence, and lots of sweat.  So we
> appreciate that it can be difficult for a CA to commit to the kind of
> improvement that, unfortunately, many of us still clearly need.
>
>
>
> Sectigo would like to help.  Looking at the behaviors of the WebPKI CA
> community, we perceive a common tendency for CAs not to understand the
> importance of self-improvement, or know how to go about it, or even
> recognize the incredible privilege they have as stewards of public trust.
> We see CAs treating the short-term and short-sighted desires of their
> corporate owners and local governments as more important than
> five-and-a-half billion internet users around the globe.  We routinely see
> CAs placing their Subscribers’ convenience over the good of the WebPKI.
>
>
>
> We see these things, and we have chosen to act.  We are trying to show CAs
> that self-improvement not only is possible but is an asset to the strength
> of your operation.  We are trying to spur improvement through encouragement
> and information sharing and where necessary strong rhetoric.  We try to
> provide concrete coaching while challenging our fellows to become their
> better selves.
>
>
>
> This is a learning process for us.  A sad fact is that many CAs appear
> quite intractable and unreceptive.  But we also see wins, instances where
> some CA will experience an authentic “light bulb” moment or a change of
> heart.  So we know it’s possible to connect in that way.  At least on
> occasion we see the idea of “CAs helping CAs” actually work.
>
>
>
> Doubtless we have made and will continue to make errors along the way, as
> we try to figure out how to be sherpas to other CAs who don’t have the
> benefit of our last five years’ experience.  Surely some will never
> appreciate it, or value it, or care in any way.  Or for that matter
> improve.  But some already have.  This makes us think that, however
> preliminary our efforts and inconsistent the results, there is something
> here worth pursuing.
> On Friday, February 7, 2025 at 12:34:00 PM UTC-5 Jeremy Rowley wrote:
>
>> Thanks Mike! Sorry again about the Sectio comment. My own interest
>> (because my name is on them) in closing these bugs is pretty obvious....
>> Not an excuse by any means, but I know it is the main reason I reacted so
>> poorly.
>>
>> Overall, I think a lot of the CAs are confused about what they need to do
>> to close the bug. I think with the delayed revocation bugs in particular,
>> there's a lack of clarity on what the community needs to close the bug as
>> resolved considering it was a conscious decision by the CA to delay
>> revocation. Although I do not represent a CA, I cannot think of what the CA
>> can say or do to ensure that delayed revocation doesn't happen again,
>> especially when you can't get browsers to say "Delayed revocation is never
>> acceptable".  Is there a bug with intentional delayed revocation where the
>> action items are ones that were good technical controls to ensure it didn't
>> happen again? I'm struggling to think of any that give real good reasons on
>> how delayed revocation won't happen again outside of just promising "No
>> more delayed revocation".
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1945389 - No comments so far
>>>
>>
>> >> To me this doesn't mean "there is nothing to do with this bug" but
>> more likely "in the 5 days since it opened, nobody has bothered to ask
>> anything ahead of the full incident report". These days I'm trying to focus
>> my limited root-meddling time on inadequate action items, so I generally
>> don't bother with preliminary incident reports because I would have to
>> guess what the flaws in the future action items would be.
>>
>> Yeah - I agree this one needs more time and attention. It isn't old and
>> should not be closed.
>>
>>
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1943528 - Entrust was
>>> distrusted so no need to keep it open
>>>
>>
>> >> The purpose of a delayed revocation incident is not only to provide
>> root programs with visibility into the practices and reliability of CAs. It
>> is also to ensure that all (ahem, remaining) CAs have the opportunity to
>> learn from the incident such that they might avoid a similar incident in
>> the future. Entrust being distrusted does not necessarily mean that there
>> is no value in further discussion of the incident, and indeed I think
>> generally many incidents are pretty poorly reasoned and explained in those
>> matters.
>>
>> Makes sense. Is Entrust going to keep responding now that they have sold
>> the business to Sectigo? I realise Entrust still owns the roots which means
>> we need them to reply to the comments going forward.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1942879 - Issue identified
>>> and the delay was unintentional
>>>
>>
>> >> Note that in this case the issue was "malware filtering blocked CPR",
>> which was sufficiently distinct from "spam filter blocked CPR" that
>> multiple CAs did not extrapolate from the latter to the former when
>> monitoring previous incidents. This makes me feel that perhaps more
>> attention could be paid by the root programs to explaining how they expect
>> CAs to address classes of issue, rather than just the most
>> narrowly-interpreted case specifically implicated in an incident. Closing
>> the bug ahead of that clarity coming from root programs or, failing that,
>> peer CAs or other community members, seems like a missed opportunity to
>> avoid future incidents like "we block things that have a non-ASCII sender
>> name" or whatever the next fine speciation would be.
>>
>> I think so too. Be good to get clarity on how to address different
>> situations. IMO, an intentional delay of revocation is more egregious than
>> something like this where a tool blocked the CPR. I think it's far more
>> acceptable where a technical solution caused the issue instead of a human
>> doing something wrong as it shows the CA has technology in place to control
>> security and (hopefully) automate a lot of the process.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1916478 - Delay appears
>>> unintentional and was an operational issue
>>>
>>
>> >> This is a great example of where the work hasn't been done to make the
>> incident useful for other CAs. It contains the old canards about "improving
>> procedures" and "training staff", but doesn't detail exactly what was wrong
>> with the previous policies or training, or—more importantly—what caused the
>> training or policies to have those defects in the first place. Without
>> that, all a CA can take away is "have procedures and train staff" which, I
>> still permit myself to hope, they all understand at that level of detail
>> already.
>>
>> Agreed on this one. Unintentional delays need technical controls to
>> prevent them from reoccuring. This one doesn't have technical controls.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1898848 - Acknowleded that
>>> it was a mistake to delay yet Tim keeps pushing
>>>
>>
>> >> I don't see Tim continuing to push in this bug at all. The last
>> comment was some time ago, and the discussion seems to mostly have been
>> between Entrust representatives and Wayne.
>>
>> You're right. This one is one I would close though.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1889062 - Acknowledges that
>>> it was against the BRs to delay
>>>
>>
>> >> This one is definitely not done, given that the subscriber rationale
>> was given as "these agencies take too long to replace stuff and they're
>> very important in some way", and there was nothing specific in the action
>> items or otherwise to indicate how GDCA will navigate that tension in the
>> future other than "encouragement" or "make a policy (of unspecified
>> contents)".
>>
>> Okay - what action item should they have?
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1888882 - Comment 28 pretty
>>> much states that will ensure awareness of teh 5 day requirement
>>>
>>
>> >> Yep, for sure *this* time, "customer education" will be sufficient. :P
>> "When users apply for or obtain certificates, they will be clearly informed
>> of the revocation scenarios and time limits" is the sort of thing that's
>> hard for me to take seriously when the BRs already required that the
>> Subscriber make a legally binding commitment to that effect.
>>
>> I think these are hard as I know customers cite the previous Mozilla
>> policy as allowing delayed revocation. Getting rid of that language will be
>> a significant boon.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1887888 - This one never
>>> answered the question of what they will do going forward.
>>>
>>
>> >> Indeed. Seems like closing in that situation would send an unfortunate
>> message that you can just wait it out and the awkward questions will go
>> away.
>>
>> Yeah - I definitely agree with this one.
>>
>> On Fri, Feb 7, 2025 at 8:41 AM Mike Shaver <[email protected]> wrote:
>>
>>> Hi Jeremy,
>>>
>>> I don't agree with your listed reasoning for these bugs all being
>>> suitable for closure, though I do genuinely appreciate you taking the time
>>> to enumerate them like this. Some responses to selected entries below!
>>>
>>> On Thu, Feb 6, 2025 at 4:58 PM Jeremy Rowley <[email protected]> wrote:
>>>
>>>> Perhaps it would be better to look at each delayed revocation bug:
>>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1945389 - No comments so
>>>> far
>>>>
>>>
>>> To me this doesn't mean "there is nothing to do with this bug" but more
>>> likely "in the 5 days since it opened, nobody has bothered to ask anything
>>> ahead of the full incident report". These days I'm trying to focus my
>>> limited root-meddling time on inadequate action items, so I generally don't
>>> bother with preliminary incident reports because I would have to guess what
>>> the flaws in the future action items would be.
>>>
>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1943528 - Entrust was
>>>> distrusted so no need to keep it open
>>>>
>>>
>>> The purpose of a delayed revocation incident is not only to provide root
>>> programs with visibility into the practices and reliability of CAs. It is
>>> also to ensure that all (ahem, remaining) CAs have the opportunity to learn
>>> from the incident such that they might avoid a similar incident in the
>>> future. Entrust being distrusted does not necessarily mean that there is no
>>> value in further discussion of the incident, and indeed I think generally
>>> many incidents are pretty poorly reasoned and explained in those matters.
>>>
>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1942879 - Issue
>>>> identified and the delay was unintentional
>>>>
>>>
>>> Note that in this case the issue was "malware filtering blocked CPR",
>>> which was sufficiently distinct from "spam filter blocked CPR" that
>>> multiple CAs did not extrapolate from the latter to the former when
>>> monitoring previous incidents. This makes me feel that perhaps more
>>> attention could be paid by the root programs to explaining how they expect
>>> CAs to address classes of issue, rather than just the most
>>> narrowly-interpreted case specifically implicated in an incident. Closing
>>> the bug ahead of that clarity coming from root programs or, failing that,
>>> peer CAs or other community members, seems like a missed opportunity to
>>> avoid future incidents like "we block things that have a non-ASCII sender
>>> name" or whatever the next fine speciation would be.
>>>
>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1916478 - Delay appears
>>>> unintentional and was an operational issue
>>>>
>>>
>>> This is a great example of where the work hasn't been done to make the
>>> incident useful for other CAs. It contains the old canards about "improving
>>> procedures" and "training staff", but doesn't detail exactly what was wrong
>>> with the previous policies or training, or—more importantly—what caused the
>>> training or policies to have those defects in the first place. Without
>>> that, all a CA can take away is "have procedures and train staff" which, I
>>> still permit myself to hope, they all understand at that level of detail
>>> already.
>>>
>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1898848 - Acknowleded
>>>> that it was a mistake to delay yet Tim keeps pushing
>>>>
>>>
>>> I don't see Tim continuing to push in this bug at all. The last comment
>>> was some time ago, and the discussion seems to mostly have been between
>>> Entrust representatives and Wayne.
>>>
>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1889062 - Acknowledges
>>>> that it was against the BRs to delay
>>>>
>>>
>>> This one is definitely not done, given that the subscriber rationale was
>>> given as "these agencies take too long to replace stuff and they're very
>>> important in some way", and there was nothing specific in the action items
>>> or otherwise to indicate how GDCA will navigate that tension in the future
>>> other than "encouragement" or "make a policy (of unspecified contents)".
>>>
>>>
>>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1888882 - Comment 28
>>>> pretty much states that will ensure awareness of teh 5 day requirement
>>>>
>>>
>>> Yep, for sure *this* time, "customer education" will be sufficient. :P
>>> "When users apply for or obtain certificates, they will be clearly informed
>>> of the revocation scenarios and time limits" is the sort of thing that's
>>> hard for me to take seriously when the BRs already required that the
>>> Subscriber make a legally binding commitment to that effect.
>>>
>>> Also, that report describes an action item (maybe? a commitment at
>>> least) that was to be completed a month ago, and for which no status has
>>> been given:
>>>
>>> > This action plan will take a long time, but we will still accelerate
>>> the progress to encourage as many of our existing customers with larger
>>> certificate volumes to use the automated certificate deployment system as
>>> much as possible by 2025.
>>>
>>> Unless the goal is just to complete the *encouragement* by 2025, in
>>> which case it's a nothing-burger again.
>>>
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1887888 - This one never
>>>> answered the question of what they will do going forward.
>>>>
>>>
>>> Indeed. Seems like closing in that situation would send an unfortunate
>>> message that you can just wait it out and the awkward questions will go
>>> away.
>>>
>>>
>>>> The value to Sectigo and the Sectigo podcast is pretty obvious,
>>>>
>>>
>>> This is bullshit, unwelcome on the list, and quite surprising. I know
>>> you apologized but I still can't let it just go by when I'm replying to the
>>> message.
>>>
>>> Mike
>>>
>>>

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