In case people have missed it, this particular topic was discussed at the last CA/B Forum F2F meeting <https://cabforum.org/2025/03/27/minutes-of-the-f2f-64-meeting-in-tokyo-japan-forum-level-march-25-26-2025/#panel-qa-with-all-guest-speakers>. I believe you will find useful information about the TRO process, especially in the United States, in Brian Holland's presentation <https://cabforum.org/2025/03/27/minutes-of-the-f2f-64-meeting-in-tokyo-japan-forum-level-march-25-26-2025/1-CABF%20-%20Dealing%20with%20TROs%2020250325.pdf>.

One thing I recall from that discussion is that when a TRO is dismissed, the reasons of that dismissal are documented, especially if the TRO was granted on wrong basis, making it unlikely that another court will issue a TRO with the same justification as the previous one that got dismissed.

The fact that a TRO was issued to prevent certificates from being revoked doesn't necessarily mean that it will be an event that can be reproduced, especially if a court later reviews the case and dismisses the TRO after considering all the facts.

Dimitris.

On 10/6/2025 10:09 π.μ., 'Roman Fischer' via [email protected] wrote:
Dear Community,

My professional ethic guidelines prohibit me from putting contracts over the 
law. Forcing people (CAs are still run by humans) to knowingly ignore the law 
just because otherwise their business will be destroyed by exclusion from root 
stores, is IMHO unethical.

Kind regards
Roman

-----Original Message-----
From:[email protected] <[email protected]> On 
Behalf Of Matt Palmer
Sent: Samstag, 7. Juni 2025 05:53
To:[email protected]
Subject: Mitigations needed for legal action imposing delayed revocation

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?

Inhttps://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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