Comments:

  *   I have issues with the draft's emphasis on fixed SPI values.  One reason 
for the SPI value is to handle key updates cleanly; during the transition, the 
SPI can be used to indicate whether the packet was encrypted with the previous 
set of key or the new ones.  As we really don't want to discourage rekeying I 
would suggest that, instead of talking so much about fixed SPIs, you instead 
address how to do nonrandom SPIs (for example, by having the top 3 bytes of the 
inbound SPI being the SAD entry, and the lower byte being the rekey index).
  *   "Values 0-255 SHOULD NOT be used."; shouldn't that be MUST NOT?  Can you 
think of an advantage a device might have for using a SPI in that region?

The use of fix SPI MUST NOT be considered as a way to avoid strong random 
generators.  Such generator will be required in order to provide strong 
cryptographic protection"; actually, if the IPsec implementation doesn't 
actually generate its own keys (that is, it relies on an external service to 
provide them), and the transform itself doesn't require random data (CBC can be 
implemented securely without one), then the IPsec implementation doesn't 
actually need an CSPRNG.

  *   SN based on clocks; one issue that is not addressed is that standard 
receivers are tuned for an increment of one-per-packet; if the sender uses 
increments significantly larger than that, and packets are reordered, the 
receiver is more likely to reject valid packets because they fell outside the 
window.
  *   One issue you do not address (but I believe you should) is the fact that 
some cryptographical transforms are more resilient for key reuse (e.g. because 
you use a fixed key, and don't change it after a reboot) than others.  In 
particular, both GCM and ChaCha20-Poly1305 have real problems when that 
happens, and should be avoided.

Typos:

  *   a random SPI may consume to much -> too much
  *   fix SPI -> fixed SPI
  *   can be alleviate -> can be alleviated
  *   algorythm -> algorithm
  *
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