Tim H, you are chairing the Validation Working Group now – can the VWG take up 
possible revisions to BR 3.2.2.4.1 as an agenda item?

From: Public [mailto:public-boun...@cabforum.org] On Behalf Of Adriano Santoni 
via Public
Sent: Wednesday, January 3, 2018 5:12 AM
To: public@cabforum.org
Subject: [EXTERNAL]Re: [cabfpub] Verification of Domain Contact and Domain 
Authorization Document


I also concur with Mads, and would support the addition of more requirements to 
method 3.2.2.4.1.

I like the solution proposed by Mad, but (if I am not mistaken) there is not a 
specific Whois record field for that information (org number), and I would 
avoid inserting that information in a field that's not expressly designed for 
it.

Other solutions may also work, and would be easier to implement, like e.g. 
mandating a full Registrant address, in the Whois record, which must be one of 
the official addresses of the Registrant as found in a QIIS/QGIS (excluding, 
however, all information sources that just publish self-reported organization 
information, which cannot be regarded as "qualified" information sources and 
IMO should not be used in the vetting process), and then the "reliable method 
of communication" should be one that is found in the matching QIIS/QGIS record.

Not sure about method 3.2.2.4.5, at this time, as I have not yet seen a 
sufficient discussion on it, and I am not sure how it can effectively be used 
"as is" to obtain a fraudulent certificate.
Adriano


Il 03/01/2018 13:27, Doug Beattie via Public ha scritto:
I agree with Mads and am also supportive of a ballot that removes 3.2.2.4.5 and 
adds some more detail to 3.2.2.4.1.

Doug

From: Public [mailto:public-boun...@cabforum.org] On Behalf Of Mads Egil 
Henriksveen via Public
Sent: Wednesday, January 3, 2018 7:11 AM
To: Jeremy Rowley 
<jeremy.row...@digicert.com><mailto:jeremy.row...@digicert.com>; CA/Browser 
Forum Public Discussion List <public@cabforum.org><mailto:public@cabforum.org>; 
geo...@apple.com<mailto:geo...@apple.com>
Subject: Re: [cabfpub] Verification of Domain Contact and Domain Authorization 
Document


Then I think we should change the requirements.

As a representative for a CA with a background in strong identity validation 
(both for natural and legal persons) I find these examples from Ryan and Jeremy 
to represent a very bad practice. If this really reflects the current practice 
in the industry, we need to tighten up the requirements and make them much more 
specific.

From my point of view (and with my background) I find method 3.2.2.4.1 useful. 
We must remember that the domain validation methods also are used for EV (and 
not only OV) and when we have a strongly validated and verified organization 
(e.g. based on the EV requirements) it makes sense to allow for the 
organization to apply for certificates including domain names owned by the 
organization itself.

I understand that there are doubts about how to ensure that the organization 
really owns the domain (like in Jeremy’s example), but it should not be too 
hard to “strengthen” the link between the applicant and the domain owner in 
terms of rewriting section 3.2.2.4.1. A match in the organization name only 
should of course not be allowed.

In Norway every organization is given a unique organization number by a 
national authority and in the registry for the TLD=.no domains (see 
www.norid.no<http://www.norid.no>) we find this organization number as a part 
of the domain name registrant information. In such cases, we allow for issuance 
based on 3.2.2.4.1 if the domain name registrant information exactly match 
organization information (i.e. by country, organization name and organization 
number).  I think this is a reasonable use case for method 3.2.2.4.1.

Personally I am more concerned about the possibility we give to any stakeholder 
in the ecosystem who takes a role in controlling a domain to get an OV (and EV) 
certificate based on domain control only. This was discussed also in the F2F 
meeting in Bilbao last year – see 
https://cabforum.org/2016/05/25/2016-05/#The-Role-of-Identity-in-TLS-Certificates.

Therefore, I am supportive for a ballot which removes 3.2.2.4.5 and keep 
3.2.2.4.1 but strengthen this up to allow for use cases like the one described 
above.

Regards
Mads

From: Public [mailto:public-boun...@cabforum.org] On Behalf Of Jeremy Rowley 
via Public
Sent: onsdag 3. januar 2018 05:47
To: geo...@apple.com<mailto:geo...@apple.com>; CA/Browser Forum Public 
Discussion List <public@cabforum.org><mailto:public@cabforum.org>
Subject: Re: [cabfpub] Verification of Domain Contact and Domain Authorization 
Document

I disagree. The requirements do not specify that.  All that is required is the 
name of the applicant was verified under 3.2.2.1 and that the register specify 
the domain contact is the applicant. If Google, Inc. is specified as the domain 
contact, no address matching is required.

From: geo...@apple.com<mailto:geo...@apple.com> [mailto:geo...@apple.com]
Sent: Tuesday, January 2, 2018 4:34 PM
To: Jeremy Rowley 
<jeremy.row...@digicert.com<mailto:jeremy.row...@digicert.com>>; CA/Browser 
Forum Public Discussion List <public@cabforum.org<mailto:public@cabforum.org>>
Cc: Ryan Sleevi <sle...@google.com<mailto:sle...@google.com>>; Adriano Santoni 
<adriano.sant...@staff.aruba.it<mailto:adriano.sant...@staff.aruba.it>>
Subject: Re: [cabfpub] Verification of Domain Contact and Domain Authorization 
Document



On Dec 22, 2017, at 12:09 PM, Jeremy Rowley via Public 
<public@cabforum.org<mailto:public@cabforum.org>> wrote:

The attack vector is easier than that.

  1.  I use very stringent processes to verify that Google, Inc. is a legit 
company in Utah.
  2.  I verify that Jeremy did indeed incorporate Google, Inc.
  3.  I call Jeremy at the phone listed for Google, Inc., the Utah corporation
  4.  The domain information shows Google, Inc. as owning 
google.com<http://google.com/>
  5.  Certificate issues.

Obviously this would be caught in every CA’s high risk checks, but the point 
remains valid. Regardless of the expertise and thoroughness of the org check, 
the specs lack any time between the verified org and the actual domain because 
orgs are not unique on a global basis.


For item 4, you have to verify that “the Applicant is the Domain Contact”.  
Obviously it’s insufficient to just compare names—you must verify every element 
of the WHOIS contact matches the Applicant, that’s typically name, postal 
address, phone number, and e-mail.





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