On Dec 23, 5:09 am, Frank Hecker <hec...@mozillafoundation.org> wrote:
> There are two general reasons for pulling a root, to address a clear and
> present danger to Mozilla users, and to punish a CA and deter others. My
> concern right now is with the former. I see at least three issues in
> relation to that:
>
> 1. Issuance of further non-validated certs by this reseller. Comodo
> seems to have addressed this by suspending the reseller's ability to get
> certs issued. (I can testify that this is the case, as I tried to
> duplicate Eddy's feat earlier today and got my uploaded CSR rejected.)
>
> 2. Potential problems with certs already sold through this reseller.
> Comodo should investigate this and take action if needed. (This need not
> necessarily require revoking all certificates associated with the
> reseller; for example, the existing certs and their associated domains
> could be re-validated, the registered domain owners could be notified of
> the potential for bogus certs floating around, etc.)
>
Frank,
We are in the process of reviewing all of the certificates that have
been issued where Certstar served as a RA for Comodo. Fortunately they
have only been involved in the validation of 111 certificates.  As I
previously mentioned as soon as we discovered the error with the
Mozilla.com certificate we suspended Certicom’s RA privileges.
Certstar’s RA activities remain suspended.

At this point it appears that the Mozilla and Startcom certificates
were an anomaly, the result of the automatic DCV mechanism being
bypassed by accident.  Certstar’s account will remain suspended until
we are satisfied that the certificates issued for Mozilla and Startcom
were as Certstar maintains, the result of unintentional mistakes that
have been corrected with safeguards in place to prevent a
reoccurrence. Should Comodo decide to reinstate Certstar as an RA we
will review each certificate request until we are satisfied that
Certstar has been adequately trained and that yesterday’s mistake
cannot be duplicated.

Comodo has been able to verify that 73 of the 111 orders processed by
Certstar were processed pursuant to the requirements of our CPS and
our webhost RA terms and conditions.  We should have our review of the
remaining 38 certificates completed by tomorrow evening.  If we are
unable to verify any validation, we will revoke the applicable
certificate.


> 3. Potential problems with other Comodo resellers. I'm not going to tell
> Comodo how to operate its reseller network, but they certainly should
> take a look at whether and where this might be a problem with other
> resellers, and how they could revamp their systems to reduce potential
> problems with resellers.
>
Comodo takes it responsibility to supervise RAs very seriously and we
actively audit their performance. While it is not practical to audit
100% of their work, we audit a representative sample.  In the past we
have discovered only a few isolated incidents where our sub CAs or RAs
failed to follow the applicable guidelines.  When this has occurred we
have suspended the account, performed additional audit activities and
where appropriate revoked certificates. We are confident that our
existing system works well and are constantly looking for ways to
improve it.

We apologize for Certstar’s mistake and assure you that we will
redouble our self-auditing efforts to insure the problem does not
repeat itself.

Regards
Robin Alden
Comodo
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