Wouldn't court just force CA to unrevoke TRO'ed certificate in that case? 
Revoking a cert is just publiching a CRL/OCSP response, and I thing court 
can forbid CA to publich CRL/OSCP that says cert X is revoked as part of 
TRO. un-revoke is just publishing new CRL without that cert/send "Good" on 
OCSP, both of which aren't impossible in technicall sense, just being 
another BR violation which court doesn't care.

2025년 6월 7일 토요일 오후 12시 53분 29초 UTC+9에 Matt Palmer님이 작성:

> Given the impending closure of
> https://bugzilla.mozilla.org/show_bug.cgi?id=1910805, it would be
> disappointing if one of the more novel aspects of that incident (which
> has not been mentioned at all in the closure request summary) were left
> completely unaddressed. Given the desire expressed in the recent
> roundtable that policy questions should be discussed here, rather than
> in Bugzilla issues, I'm starting this thread.
>
> The specific policy issue I wish to discuss is the use of a Temporary
> Restraining Order (TRO) or other legal action to prevent the CA from
> performing a necessary security function by revoking misissued
> certificates. The closure summary for the incident in question makes no
> mention of this aspect of the incident, for reasons about which I can
> only speculate, but I believe that it is of crucial importance that it
> be addressed, lest TROs become the weapon of choice for ill-prepared
> subscribers to do an end-run around revocation as a security control.
>
> Those who wish the full context can read the issue (and its progenitor,
> https://bugzilla.mozilla.org/show_bug.cgi?id=1910322), but in brief:
>
> * Alegeus Technologies, a customer of DigiCert, was issued several
> certificates (the legal filings indicate the number was 72) which
> required, under the BRs, revocation within 24 hours.
>
> * Within that 24 hour period, Alegeus filed a TRO blocking DigiCert from
> revoking those misissued certificates.
>
> * Some time after the 24 hour period had passed, the parties agreed to
> drop the TRO and the revocation took place, at substantially the same
> time as the other 80k+ misissued certificates were revoked.
>
> Given that all the misissued certificates were revoked at around the
> same time, there is no public indication that the TRO caused DigiCert to
> specifically delay revocation of the Alegeus certificates. However,
> given the references to "future legal strategy to combat such actions"
> (https://bugzilla.mozilla.org/show_bug.cgi?id=1910322#c33), I think it's
> reasonable to assume, prima facie, that a TRO would have been an
> effective means to block DigiCert from revoking the Alegeus
> certificates, even if DigiCert had intended to revoke the other
> misissued certificates on time.
>
> Which brings us to the crux of the problem. The certificates were
> misissued. For various good security reasons, they were required to be
> revoked within 24 hours. The legal system was used in an attempt to
> prevent that, risking harm to relying parties by the continued validity
> of those misissued certificates.
>
> The parties on the "front line" of this problem, the CAs, have not
> provided any meaningful public information (that I've seen, anyway) on
> how they might avoid this problem. Thus, it devolves to relying parties
> (in the form of their representitives, the trust stores, and
> specifically Mozilla) to take action to prevent this problem from
> recurring.
>
> Thus, the question is: what can the WebPKI do to prevent such things from
> happening in the future, and mitigating the risk inherent in such
> actions?
>
> In https://bugzilla.mozilla.org/show_bug.cgi?id=1910805#c40, I made a
> couple of off-the-cuff suggestions, which I will expand upon to provide,
> if nothing else, a basis for discussion. I don't claim any of these are
> part of a "right" answer, but I do assert that they are all *possible*
> answers. As I acknowledged in my original comment, these suggestions
> impose some potentially unpleasant consequences for CAs, but the
> available options for trust stores and relying parties are rather
> limited.
>
> Firstly, the time limit for revocation could be reduced to such a period
> that revocation would be required before any subscriber could manage to
> obtain a legal order preventing revocation (which, for the ease of
> reading, I will refer to hereafter as a TRO, even though various legal
> means could be used). As a TRO cannot prevent something that has
> already happened, it becomes a moot point even if a subscriber managed
> to get one.
>
> Of course, this change would have significant consequences for CAs and
> subscribers. CAs would be required to have sufficient staff to handle
> problem reports on a much shorter timescale, and staff would need to be
> trained better to be able to handle them quickly enough. Subscribers
> would get much less notice, and would have to improve their processes to
> be able to receive and respond to "pending revocation" notices much
> quicker. Automated systems, such as ARI, would need to be
> over-provisioned and updated such that they were able to handle the much
> greater load of clients checking (and possibly requesting reissuance) on
> a much shorter timescale.
>
> Another option would be to make the consequences for delayed revocation
> severe and mandatory. In short, fail to revoke within the specified
> time period, and you're out of the trust store, no exceptions. This
> would change the calculus for a CA which received a TRO requiring
> delayed revocation -- they can either obey the TRO, and _know_ that
> they're going to be removed from trust stores (with the consequent
> impacts on their business), or they can breach the TRO and take
> their chances with the court.
>
> Again, this would have significant consequences. I recognise that there
> are (extremely limited) circumstances in which a delayed revocation
> _may_ not warrant immediate distrust. However, attempts to codify these
> circumstances would inevitably lead to attempts to "rules-lawyer"
> revocations into one of the "acceptable" circumstances, and if CAs
> believed there was a chance of being able to argue their way out of a
> delayed-revocation distrust action, they may choose that route rather
> than choosing to maintain the security of the WebPKI. Thus, the only
> reasonable option is for the rule to be "delaying revocation means
> distrust", and live with the consequences of such a rule.
>
> I'd like to reiterate that these ideas are not necessarily "the answer".
> However, it would be extremely disappointing if this loophole were not
> closed. Ill-prepared subscribers will use any means they can to avoid
> the consequences of their (lack of) actions, and if a TRO will do the
> trick, I'm confident that it will be used again in the future.
>
> Thanks,
> - Matt
>

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