Robin, I have a request to make. Lets put aside for a minute the 
procedural matters and let me ask you a few questions:

- We are not seeking to cause any harm to Comodo or unilaterally remove 
the roots from NSS. However can we seek the cooperation on the issues 
which were raised and is Comodo willing to address this issues in good 
faith?

- Apparently you agree that the major issues we've raised, indeed pose a 
higher risk to the relying parties. Can we work together in order to 
improve your products to the extend that both sides can live with it and 
based on reasonable terms? This would improve the overall quality of all 
certificates issued by CAs which are included in NSS, which would result 
in further strengthening of digital certification in general and in 
Mozilla software in particular. It would improve also your standing in 
this industry!

- Any conclusions through this process and any update to the Mozilla CA 
policy would be evenly applied upon all CAs included in NSS. 
Additionally, other software vendors, most notably Microsoft could adopt 
them as well, resulting in a major improvement of our industry. Under 
this condition, would you be willing to seriously address the issues, 
make and amend changes to your CPS and implement the changes at your CA?


The issues which should be addressed are certificates with a longer 
validity and domain validated wild card certificates. I would like to 
make the following suggestions, that

- domain validated certificates which are valid for more than 24 month, 
must be re-validated every year thereafter (starting after 24 month). 
Should revalidation fail, the certificate shall be suspended until the 
subscriber has done so successfully or revoked. This would leave your 
product intact and you could continue to issue them as you do today, 
however would introduce additional validations during the life time of 
the certificate.

- domain validated wild card certificates would undergo an additional 
identity validation. The certificates content itself doesn't have to be 
changed compared to what you do today (if you prefer), but you would 
guaranty through your CPS that you perform this additional validation.


Are these suggestions reasonable in your point of view and would this be 
acceptable to the management of Comodo? Could Comodo commit and agree to 
such an implementation, provided that this will be evenly applied upon 
all CAs currently in NSS? If not, can you please provide an alternative, 
solving the issues at hand and explain what Comodo would be willing to 
implement instead?


-- 
Regards 
 
Signer:         Eddy Nigg, StartCom Ltd. <http://www.startcom.org>
Jabber:         [EMAIL PROTECTED] <xmpp:[EMAIL PROTECTED]>
Blog:   Join the Revolution! <http://blog.startcom.org>
Phone:          +1.213.341.0390
 

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