Re: Unbelievable!

2008-12-26 Thread Kyle Hamilton
https://bugzilla.mozilla.org/show_bug.cgi?id=426575

UTN-UserFIRST-Hardware is enabled for EV per that bug.

-Kyle H

On Thu, Dec 25, 2008 at 9:59 AM, Frank Hecker
hec...@mozillafoundation.org wrote:
 Kyle Hamilton wrote:

 What is the effect of this problem on the request to enable the
 UTN-UserFirst-Hardware root for EV,
 https://bugzilla.mozilla.org/show_bug.cgi?id=401587 ?

 I think (but don't have time to confirm right at the moment) that that
 request is moot. As far as I know, Comodo EV certificates are working fine
 right now even in the absence of the UTN-UserFirst-Hardware root being
 enabled for EV. This is due to EV-enabling of the new Comodo EV root and
 also IIRC due to code that was added to PSM (?) to specially handle cases
 like this where the EV root was cross-signed by a non-EV legacy root.

 (AFAIK this scenario was/is not unique to Comodo. I believe all the VeriSign
 EV CAs work this way as well: a newly added and EV-enabled EV root
 cross-signed by a non-EV legacy root.)

 Frank

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Re: Unbelievable!

2008-12-26 Thread robin
On Dec 24, 2:13 am, Paul C. Bryan em...@pbryan.net wrote:
 On Dec 23, 5:56 pm, ro...@comodo.com wrote:
 Some questions:

 1. Does Comodo take full responsibility for the actions of its
 resellers? If so, how should the repercussions of such failures be to
 Comodo?
Comodo accepts responsibility for the work of its RAs in the
validation that they do leading to the issuance of certificates under
our root certificates.


 2. Are resellers subject to the same audits that Comodo presumably had
 to undergo to get its root certs added to Mozilla? Who performs, and
 who verifies such audits? How often are they performed?
No, the RAs are not subject to the same audits as Comodo.  Comodo
undergoes an annual external audit to maintain our Webtrust
certification for CAs.
http://www.cica.ca/download.cfm?ci_id=45239la_id=1re_id=0
https://cert.webtrust.org/ViewSeal?id=804


 3. Are you willing to openly, continually disclose your list of
 resellers, the frequency of audits, audit methodology, and actual
 audit reports so that third parties can evaluate whether Comodo is
 trustworthy as a CA?
That is a question combined with an assertion.
To the question: on a unilateral basis, no, Comodo wouldn't reveal
that level of detail of our internal operation.  If all CAs were
required to provide the information, either to retain Webtrust
certification or to gain or retain access to the root program of a
major browser or other platform, then we would reconsider.
To the assertion that this is a pre-requisite for a CA to be
trustworthy: I am not aware that it is Mozilla's policy to require
this information to be disclosed.
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Re: Unbelievable!

2008-12-26 Thread Kyle Hamilton
See, Robin, my thought is this:

You've already shown that it's possible for the RA function to bypass
all controls.  At this point, because they're not subject to the same
audits that Comodo is, and because the last WebTrust audit that anyone
here can find any record of is in 2007, I find it difficult to believe
that you have the annual external audit.

The internal controls are supposed to prevent this kind of
mis-issuance.  Because they didn't, they throw all the audits that you
have provided into doubt.  Because of this, there is no trust that I
have in Comodo's operation.

Further, this is a problematic practice (delegation of Registration
Authority function, as opposed to simple reseller role) that has
been shown to cast doubt on the entire domain.

The Registration Authority function is terribly security-sensitive.
If the whistle had not been blown by someone who knew where to post to
kick the beehive, would this have been detected?  Since the RAs aren't
audited (which is, by the way, a TERRIBLY dangerous practice, as
you're seeing), and your statements about a representative sample of
certificate requests are reviewed suggesting that they're not even
properly audited by your internal controls...

It is not necessarily a requirement for reseller information to be
disclosed.  However, we're trying to evaluate your company's continued
trustworthiness, and (at least at the moment) I can't find anything
there to trust.  I'm willing to allow your eleven roots to stay in the
root store with trust bits removed until you provide documentation and
an update to your agreement with your RAs to require on-site audits at
least annually (even if done by your internal auditors) -- the only
alternative at this point is to completely remove your roots from the
program.

I would like to know how you're going about ensuring that none of your
other RAs are subject to the same 'glitch' in their signup processes.
I'd like to hear that you're being proactive about this issue.

Unfortunately, I'm not hearing such.

-Kyle H

On Fri, Dec 26, 2008 at 1:10 PM,  ro...@comodo.com wrote:
 On Dec 24, 2:13 am, Paul C. Bryan em...@pbryan.net wrote:
 On Dec 23, 5:56 pm, ro...@comodo.com wrote:
 Some questions:

 1. Does Comodo take full responsibility for the actions of its
 resellers? If so, how should the repercussions of such failures be to
 Comodo?
 Comodo accepts responsibility for the work of its RAs in the
 validation that they do leading to the issuance of certificates under
 our root certificates.


 2. Are resellers subject to the same audits that Comodo presumably had
 to undergo to get its root certs added to Mozilla? Who performs, and
 who verifies such audits? How often are they performed?
 No, the RAs are not subject to the same audits as Comodo.  Comodo
 undergoes an annual external audit to maintain our Webtrust
 certification for CAs.
 http://www.cica.ca/download.cfm?ci_id=45239la_id=1re_id=0
 https://cert.webtrust.org/ViewSeal?id=804


 3. Are you willing to openly, continually disclose your list of
 resellers, the frequency of audits, audit methodology, and actual
 audit reports so that third parties can evaluate whether Comodo is
 trustworthy as a CA?
 That is a question combined with an assertion.
 To the question: on a unilateral basis, no, Comodo wouldn't reveal
 that level of detail of our internal operation.  If all CAs were
 required to provide the information, either to retain Webtrust
 certification or to gain or retain access to the root program of a
 major browser or other platform, then we would reconsider.
 To the assertion that this is a pre-requisite for a CA to be
 trustworthy: I am not aware that it is Mozilla's policy to require
 this information to be disclosed.
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Re: [Fwd: Follow-Up on www.verisign.com SSL Order]

2008-12-26 Thread Michael Ströder
goo...@servage.net wrote:
 On Dec 26, 5:27 pm, David E. Ross nob...@nowhere.not wrote:
 Note that the message from Certstar that Eddy posted said [emphsis added]:
 I am contacting you as I noticed that *you did completed*   your SSL 
 Certificate order forwww.verisign.comand wanted
 to follow up on it.
 
 You are right. It seems there was a typo in that email, it should of
 course have said you did not complete your SSL Certificate order as
 it is a follow up for people who do not complete the ordering process.

Looking at the

From: goo...@servage.net

line of your posting you seem to like using names possibly leading to
misunderstandings. Strange...

Ciao, Michael.
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Re: Unbelievable!

2008-12-26 Thread Eddy Nigg

On 12/26/2008 11:38 PM, Kyle Hamilton:

You've already shown that it's possible for the RA function to bypass
all controls.  At this point, because they're not subject to the same
audits that Comodo is, and because the last WebTrust audit that anyone
here can find any record of is in 2007, I find it difficult to believe
that you have the annual external audit.


Robin just gave us the link for the current WebTrust report. As I 
mentioned previously Comodo does perform a yearly audit. However, since 
no directory exists at WebTrust, the last audit I could find was the one 
published at the Pending page.


Here the new link: https://cert.webtrust.org/SealFile?seal=804file=pdf


--
Regards

Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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Re: Unbelievable!

2008-12-26 Thread Paul C. Bryan
Thanks for your response Robin.

On Dec 26, 1:10 pm, ro...@comodo.com wrote:

 Comodo accepts responsibility for the work of its RAs in the
 validation that they do leading to the issuance of certificates under
 our root certificates.

You failed to answer the other half of this question. What should the
repercussions of such failures as this be for Comodo? Simply hoping
you follow-up with your resellers (as has so far been the case with
Certstar) is not an acceptable remedy in my opinion.

 No, the RAs are not subject to the same audits as Comodo.  Comodo
 undergoes an annual external audit to maintain our Webtrust
 certification for CAs.

How can the results of the Comodo audits be considered valid if Comodo
outsources portions of its functions to third parties, that are not
subject to the same audits?

 http://www.cica.ca/download.cfm?ci_id=45239la_id=1re_id=0https://cert.webtrust.org/ViewSeal?id=804

This link responds with an error result.

 That is a question combined with an assertion.

Indeed, which I'll address below.

 To the question: on a unilateral basis, no, Comodo wouldn't reveal
 that level of detail of our internal operation.  If all CAs were
 required to provide the information, either to retain Webtrust
 certification or to gain or retain access to the root program of a
 major browser or other platform, then we would reconsider.

As I have mentioned in previous postings, a trust chain is only as
strong as its weakest link. Comodo has added extra links in its chain,
in the form of resellers whom it trusts to peform DV. If those links
in the chain are not disclosed, and not subject to the same audits as
the party applying for trust certification, then the integrity of the
chain cannot be established. I expect that no other CAs are delegating
their RA/DV functionality to third parties. If they are, then they're
in the same boat as Comodo.

 To the assertion that this is a pre-requisite for a CA to be
 trustworthy: I am not aware that it is Mozilla's policy to require
 this information to be disclosed.

I can't see how a CA can be considered trustworthy by anyone if it
outsources portions of its core operations to undisclosed parties, and
those parties are not subject to the same criteria, inspection and
audits as the CA itself.
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Re: Unbelievable!

2008-12-26 Thread Paul C. Bryan
On Dec 26, 2:18 pm, Paul C. Bryan em...@pbryan.net wrote:

 This link responds with an error result.

Apologies. Disregard my statement about the link error. I realized
it's two links. I will now go drink some more coffee to increase my
alertness level.
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Avoid incorrect issuing of Certificates

2008-12-26 Thread patricia
Hi,

Lately we have all seems that the certificate system is not 100%
secure - mistakes happen. It might never become fully bullet proof but
one simple change might help a lot.

How about creating certificate type that is registered in a central
database and require all CAs to check this DB before issuing new
certificates? Once in that database no certificates could be issued
for this specific domain. I think that most high profile sites would
take advantage of such service.

My suggestion probably needs a little fine tuning but it would be a
step in the right direction.


--
kind regards,
Patricia, Certstar ApS
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Re: Unbelievable!

2008-12-26 Thread Ian G

On 26/12/08 22:38, Kyle Hamilton wrote:

See, Robin, my thought is this:

You've already shown that it's possible for the RA function to bypass
all controls.  At this point, because they're not subject to the same
audits that Comodo is, and because the last WebTrust audit that anyone
here can find any record of is in 2007, I find it difficult to believe
that you have the annual external audit.

The internal controls are supposed to prevent this kind of
mis-issuance.  Because they didn't, they throw all the audits that you
have provided into doubt.  Because of this, there is no trust that I
have in Comodo's operation.




The internal controls are not supposed to prevent mis-issuance.  This 
is a gross consumer simplification, and has no place here.  The controls 
are meant to reduce the likelihood of them, make them discoverable, and 
deal with them when they happen.


We can no more prevent bad certs than we can stop the winter from 
coming.  The point is to put in place economically reasonable policies 
and practices that meet an appropriate balance of security versus cost.


If there has been a case where a particular instance has swayed and 
delivered too much convenience, for too high a security risk, then the 
systems will deal with it.


So far the systems are dealing with it.  Check the facts:  CA was 
notified.  Reseller frozen.  Certs revoked.  Internal audits are 
checking.  External audit might get involved.  This is what the systems 
are supposed to do.




To all:  Although we might in other contexts promote the use of open 
forums for open governance purposes -- analysis and discussion of the 
properties of providers by open parties -- *this public lynching is not 
that*.


It is neither informed, nor professional.

Mozilla runs a process where there is a one week period of public 
scrutiny of a CA.  During that time, we could reasonably argue that 
people here are invited to state their fears.  We might consider 
discussions to be more priviledged such as in parliament.


However, outside that week, there is no such protection.  Where people 
in this group have crossed the line, and made actionable statements, 
and/or done actionable harm to a business or individual, they should 
note:  it is unlikely that Mozilla, or the community, or the businesses 
as a whole will, can or should protect them.  And where corporates are 
forced to be quiet for fear of reputational damage, then it is up to the 
rest of us to seek professionalism and self-governance.




The process of recovery from this hack is not an open nor public 
process.  CAs, as businesses, and audits, as governance are not 
generally public affairs.


If you wish to advance these into the open, by all means do, but first, 
establish a policy and a practice.  Let's establish guidelines on 
reasonable behaviour so that criticism can be seen in a narrow context, 
and can be protected and informed.


Elsewise, it is unbalanced.  You can talk unprofessionally, but others 
are forced to remain silent.  Any comments are wasted, discussion is 
fruitless at best, and at worst, the mob will have their way.




iang
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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread Ian G

On 26/12/08 23:52, patri...@certstar.com wrote:


How about creating certificate type that is registered in a central
database and require all CAs to check this DB before issuing new
certificates? Once in that database no certificates could be issued
for this specific domain. I think that most high profile sites would
take advantage of such service.



I have toyed with an alternate idea which is to indicate an appropriate 
CA in the technical contact of the whois registry details.


The reason I thought of that is perhaps an unhappiness at yet another 
registry for intellectual property on the net.  But all ideas are worth 
thinking about.


iang
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Re: Unbelievable!

2008-12-26 Thread Ian G

On 26/12/08 02:28, Gen Kanai wrote:


On Dec 26, 2008, at 1:49 AM, Frank Hecker wrote:


Beyond that? It's somewhat of an open question.

Frank


Mozilla needs to have a concrete policy and procedures in place so that
there is no question as to what the penalties would be for future
actions of this kind.



Penalties ... tough talk, but what does it really mean?

Basically, all that a vendor can do is to drop the root.  (Ok, we can 
fiddle with the trust bits, but it seems a little but like fiddling to me.)


In short, it is DROP or NIX.  Can we say, blunt weapon ?  Either the 
vendor is small, so it matters not, or the vendor is huge, and it 
matters a great deal.  (In that latter case, it then matters a great 
deal to the CA.  It could be a deal killer.  E.g., bankrupcy.  Which 
means, Mozilla has to get that *right* or it faces another issue, 
further downstream.  Deep pockets plus aggressive liquidator equals 
not-nice maths.)


How does Mozo make the right decision here ?  Part of the problem in 
making it right whatever that means is that according to classical 
browser PKI it is not the responsibility of Mozo or any other vendor to 
do anything, let alone deciding what right is.


Classically, this is the policy, in a nutshell:

CA sets up.
CA gets audited.
some technical things are checked...
root is added.

It is that second part that is the clue:  the audit.  It is the audit's 
area to check whether the CA is following some sort of policy or 
practice or compliance.


So, if there is a failure, the first question to ask is whether this the 
failure is in the Audit's responsibility, or whether it is a vendor 
issue?  It might be one, or the other, or BOTH.  Certainly, in the 
current case, the vendor does not have the information to make a 
decision, whereas the Auditor might reasonably, having been in there and 
kicked the tires?



(Although I think, it is a singular observation:  there is no effective 
dispute resolution for this case or any other.  What does that say?)




iang
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Re: Unbelievable!

2008-12-26 Thread Kyle Hamilton
On Fri, Dec 26, 2008 at 3:12 PM, Ian G i...@iang.org wrote:
 (Although I think, it is a singular observation:  there is no effective
 dispute resolution for this case or any other.  What does that say?)

That there is no reason to trust a system without dispute resolution procedures.

-Kyle H
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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread patricia
On Dec 27, 12:06 am, Ian G i...@iang.org wrote:
 The reason I thought of that is perhaps an unhappiness at yet another
 registry for intellectual property on the net.  But all ideas are worth
 thinking about.

Maybe, I don't like central registries either. I just think we need to
think about if we can add an additional layer of security especially
for banks, high profile sites and others who could be phising targets.


--
kind regards,
Patricia, Certstar ApS

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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread Eddy Nigg

On 12/27/2008 12:52 AM, patri...@certstar.com:

Hi,



Patricia, even though I value your suggestion, I believe this is not the 
appropriate time and place to raise them. Please note, that you are not 
a certification authority but a reseller. It's the certification 
authority which needs to have reasonable and sufficient controls in 
place to prevent that from happening. They bear the ultimate 
responsibility.




Lately we have all seems that the certificate system is not 100%
secure - mistakes happen. It might never become fully bullet proof but
one simple change might help a lot.


I would agree with you in case I'd have had to resort to special tools 
and hacking your servers in order to overcome domain validation 
procedures. However in your case there was no validation at all. This is 
not a mistake, it's negligence from bottom to top. I believe that you 
are new to digital certification and it seems to me that you haven't 
understood the very basics of certification. However the fact that the 
issuing CA hasn't checked your implementations suggests gross negligence 
on their part and a complete failure of any controls that might have 
been in place. I believe that no such controls exist at all.




How about creating certificate type that is registered in a central
database and require all CAs to check this DB before issuing new
certificates?


Why? So that you can search the database for new customers? Do you 
believe that this would remove the burden to perform domain control 
validation? And why shouldn't I be able to get certificates for my 
domain from multiple certification authorities? Heck, your CA even 
issues certificates multiple times with the same subject line. I guess 
they won't be very happy with your proposal.



Once in that database no certificates could be issued
for this specific domain. I think that most high profile sites would
take advantage of such service.


High profile sites should use EV certificates anyway these days. 
Additionally it would require participation of all CAs, something which 
is very unlikely from happening. Otherwise a customer simply searches 
for another CA not participating...


--
Regards

Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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Re: Unbelievable!

2008-12-26 Thread Ian G

On 27/12/08 00:15, Kyle Hamilton wrote:

On Fri, Dec 26, 2008 at 3:12 PM, Ian Gi...@iang.org  wrote:

(Although I think, it is a singular observation:  there is no effective
dispute resolution for this case or any other.  What does that say?)


That there is no reason to trust a system without dispute resolution procedures.



I would be somewhat sympathetic to this  but it is kind of damning 
to the entire system.


Question is, is there a way of creating a dispute resolution system that 
would deal with the entire problem space?


Let's say you and I are in dispute, and the damages are N bucks.  We 
need someone to tell us who did what, and who does what, and who pays what.


We could envisage a forum of dispute resolution where we both agree to 
enter because we are inside this space already.  And agree to those 
liabilities.  That might work between us, but it doesn't scale.


E.g., it can't apply easily to a Firefox end-user who hasn't agreed to 
this forum.  So, if a Firefox user was ripped off because of a cert, 
then she would be shut out.  Alternatively, if she libelled a CA by 
claiming insecurities in a public blog, the CA would not be able to get 
satisfaction because she wouldn't recognise the forum.


However, maybe a partial solution is better than none?  Anything might 
be better than what we've got now...


iang
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Re: Unbelievable!

2008-12-26 Thread Eddy Nigg

On 12/27/2008 12:54 AM, Ian G:


We can no more prevent bad certs than we can stop the winter from
coming. The point is to put in place economically reasonable policies
and practices that meet an appropriate balance of security versus cost.



Yeah right! It really depends what the right balance is, ehhh?!


So far the systems are dealing with it. Check the facts: CA was
notified. Reseller frozen. Certs revoked. Internal audits are checking.
External audit might get involved. This is what the systems are supposed
to do.



The story starts before that. You are just seeing the tail, I'm seeing 
what preceded to that - or better, what did not happen and should have.


That's not up to an internal audit as if it were a well hidden bug in 
one of Comodo's system that somebody succeeded to crack. But maybe Robin 
can explain to us which failures happened at their side as they are 
taking supervision of RAs and resellers very seriously. But that's most 
likely something which we'll never know.



However, outside that week, there is no such protection. Where people in
this group have crossed the line, and made actionable statements, and/or
done actionable harm to a business or individual, they should note: it
is unlikely that Mozilla, or the community, or the businesses as a whole
will, can or should protect them.


Are you speaking in the name of Mozilla? Or in the name of the 
community? Or in the name of which business exactly?


--
Regards

Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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Re: [Fwd: Follow-Up on www.verisign.com SSL Order]

2008-12-26 Thread David E. Ross
On 12/26/2008 10:36 AM, goo...@servage.net wrote:
 On Dec 26, 5:27 pm, David E. Ross nob...@nowhere.not wrote:
 Note that the message from Certstar that Eddy posted said [emphsis added]:
 I am contacting you as I noticed that *you did completed*   your SSL 
 Certificate order forwww.verisign.comand wanted
 to follow up on it.
 
 You are right. It seems there was a typo in that email, it should of
 course have said you did not complete your SSL Certificate order as
 it is a follow up for people who do not complete the ordering process.
 
 
 --
 kind regards,
 Patricia, Certstar ApS

I have a problem with this response.  The message that Eddy quoted
appears to be a canned message (equivalent to a form letter).  This
was put into use without proper quality assurance (QA).  The whole issue
under discussion reflects a general disregard for QA, with this message
merely another example.

I find these failures of Certstar's QA processes alarming when you
consider the purpose of certificates.  That is, if you can't get a
simple canned message correct and allow several certificates to be
signed without verifying that the subscriber is authorized, what else is
amiss in your QA department?

Do you even have a QA department?  If so, is it independent of marketing
and other departments within your company?

-- 
David E. Ross
http://www.rossde.com/

Go to Mozdev at http://www.mozdev.org/ for quick access to
extensions for Firefox, Thunderbird, SeaMonkey, and other
Mozilla-related applications.  You can access Mozdev much
more quickly than you can Mozilla Add-Ons.
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Re: Unbelievable!

2008-12-26 Thread Ian G

On 27/12/08 00:53, Eddy Nigg wrote:

On 12/27/2008 12:54 AM, Ian G:


We can no more prevent bad certs than we can stop the winter from
coming. The point is to put in place economically reasonable policies
and practices that meet an appropriate balance of security versus cost.



Yeah right! It really depends what the right balance is, ehhh?!



There is no right balance just like there is no world peace.  Security 
is an economic phenomena, not a beauty pageant.




So far the systems are dealing with it. Check the facts: CA was
notified. Reseller frozen. Certs revoked. Internal audits are checking.
External audit might get involved. This is what the systems are supposed
to do.



The story starts before that. You are just seeing the tail, I'm seeing
what preceded to that - or better, what did not happen and should have.



That earlier story has no real place here, IMHO.  This is a forum for 
the discussion of technical, crypto, root and general PKI issues, by 
either dictat or convention.  It is not a forum for the airing of 
general business complaints.


https://lists.mozilla.org/listinfo/dev-tech-crypto

I elsewhere mentioned there is no general mechanism for dispute 
resolution, your earlier story might be a case in point.  Or might 
not.  Either way, here is not the place to grumble about practices of 
other businesses.




However, outside that week, there is no such protection. Where people in
this group have crossed the line, and made actionable statements, and/or
done actionable harm to a business or individual, they should note: it
is unlikely that Mozilla, or the community, or the businesses as a whole
will, can or should protect them.


Are you speaking in the name of Mozilla? Or in the name of the
community? Or in the name of which business exactly?



Having appreciated this point, a more interesting one is whether we as a 
community think about opening up the processes for more open governance, 
more open scrutiny, more stakeholder checking [1].


There seems to be an emerging consensus that more open is more better, 
in general at least.


Would we be in a position to explore a general opening of all auditing 
investigations and controls [2] ?


E.g., where Comodo or any CA completes an internal audit and creates a 
report to document that audit action, could we expect the CA or the 
internal auditor to publish this as a routine action?




iang



[1]  My thanks to Robin for underscoring that observation!  I had to 
kick myself for failing to see it.


[2]  Plausibly, such a proposal will not be accepted in time for the 
current case to be effected, but that's fine as this is a forum of 
improving processes, not dispute resolution.

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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread David E. Ross
On 12/26/2008 2:52 PM, patri...@certstar.com wrote:
 Hi,
 
 Lately we have all seems that the certificate system is not 100%
 secure - mistakes happen. It might never become fully bullet proof but
 one simple change might help a lot.
 
 How about creating certificate type that is registered in a central
 database and require all CAs to check this DB before issuing new
 certificates? Once in that database no certificates could be issued
 for this specific domain. I think that most high profile sites would
 take advantage of such service.
 
 My suggestion probably needs a little fine tuning but it would be a
 step in the right direction.

The issue at hand is not the first time issues about external RAs and
certificate sellers have been raised.  These are the issues that need to
be addressed now.

A CA should either assert in its CP that there are no RAs and resellers,
or else describe the CA's relationship with them.  By policy, the
Mozilla organization should require a CA's CP to address the following
four points (lumping external certificate sellers with RAs):

1.  The CP should detail how external registration authorities (RAs)
are approved.   

2.  The CP should detail how RAs verify subscriber identities.  


3.  The CP should detail how RAs verifies authorization of individuals
to represent organizational subscribers.


4.  The CP should detail how the CA verifies that RAs operate in accord
with the CA's policies.

The first would tell us how RAs and resellers are chosen.  The second
and third would tell us what processes are imposed on RAs and resellers.
 The fourth would tell us how the operations of RAs and resellers are
monitored.  Placing these four in a CP puts them in view of outside
auditors and subjects them -- especially #1 and #4 -- to being audited.
 All four of these trace to WebTrust criteria.  Note, however, none of
these require disclosing who are the RAs and resellers.  Instead, I'm
willing to rely on ISO 9000 principles: Say what you do, do what you
say, and prove it.

If Mozilla policies required these four points in a CP, then approval of
a CA's request for inclusion in the certificate database could depend --
 with respect to RAs and resellers -- upon (a) Mozilla's and the
public's review of the adequacy of the CP statements and (b) the
independent auditor's review of compliance with those statements.

-- 
David E. Ross
http://www.rossde.com/

Go to Mozdev at http://www.mozdev.org/ for quick access to
extensions for Firefox, Thunderbird, SeaMonkey, and other
Mozilla-related applications.  You can access Mozdev much
more quickly than you can Mozilla Add-Ons.
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Re: [Fwd: Follow-Up on www.verisign.com SSL Order]

2008-12-26 Thread Eddy Nigg

On 12/27/2008 02:33 AM, patri...@certstar.com:


This is just sales.


Patricia, I know that this is all just sales, this is what we all do 
here. But don't you think that Comodo should have helped you a little 
bit with the setup of your site?


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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread Eddy Nigg

On 12/27/2008 02:42 AM, David E. Ross:


The issue at hand is not the first time issues about external RAs and
certificate sellers have been raised.  These are the issues that need to
be addressed now.

A CA should either assert in its CP that there are no RAs and resellers,
or else describe the CA's relationship with them.  By policy, the
Mozilla organization should require a CA's CP to address the following
four points (lumping external certificate sellers with RAs):

1.  The CP should detail how external registration authorities (RAs)
are approved.   

2.  The CP should detail how RAs verify subscriber identities.  


3.  The CP should detail how RAs verifies authorization of individuals
to represent organizational subscribers.


4.  The CP should detail how the CA verifies that RAs operate in accord
with the CA's policies.

The first would tell us how RAs and resellers are chosen.  The second
and third would tell us what processes are imposed on RAs and resellers.
  The fourth would tell us how the operations of RAs and resellers are
monitored.  Placing these four in a CP puts them in view of outside
auditors and subjects them -- especially #1 and #4 -- to being audited.
  All four of these trace to WebTrust criteria.  Note, however, none of
these require disclosing who are the RAs and resellers.  Instead, I'm
willing to rely on ISO 9000 principles: Say what you do, do what you
say, and prove it.

If Mozilla policies required these four points in a CP, then approval of
a CA's request for inclusion in the certificate database could depend --
  with respect to RAs and resellers -- upon (a) Mozilla's and the
public's review of the adequacy of the CP statements and (b) the
independent auditor's review of compliance with those statements.



Seconded. BTW, this is part of the WebTrust criteria. We need to make it 
explicit similar to the intermediate CAs.


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Re: Unbelievable!

2008-12-26 Thread Paul C. Bryan
On Dec 26, 4:40 pm, Ian G i...@iang.org wrote:

With respect:

 This is a forum for the discussion of technical, crypto, root and general PKI
 issues, by either dictat or convention.  It is not a forum for the airing of 
 general
 business complaints.

Are you characterizing this issue as merely a general business
complaint?

I happen to agree that this should not be the forum for such
discussion, but as you point out, there is no other apparent forum for
dispute resolution. Where should such discussions be taken?

 Having appreciated this point, a more interesting one is whether we as a
 community think about opening up the processes for more open governance,
 more open scrutiny, more stakeholder checking [1].

My first reaction would be: most definitely, +1.

That said, you have classified this discussion as a public lynching of
a CA, called into question the professionalism of those engaging in
such discussion, and identified potential legal liabilities in doing
so.

My question to you would be: assuming the issues you raised are
legitimate (I happen to disagree) how could such an open governance
model cope with the restrictions that would most certainly be
necessary to address the issues you raised?

 Would we be in a position to explore a general opening of all auditing
 investigations and controls [2] ?

+1
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Re: Unbelievable!

2008-12-26 Thread Eddy Nigg

On 12/27/2008 02:40 AM, Ian G:

On 27/12/08 00:53, Eddy Nigg wrote:


Yeah right! It really depends what the right balance is, ehhh?!



There is no right balance just like there is no world peace. Security
is an economic phenomena, not a beauty pageant.



No, security is an inconvenience, but I've said that earlier already.



The story starts before that. You are just seeing the tail, I'm seeing
what preceded to that - or better, what did not happen and should have.



That earlier story has no real place here, IMHO. This is a forum for
the discussion of technical, crypto, root and general PKI issues, by
either dictat or convention. It is not a forum for the airing of general
business complaints.


You don't seem to get it, do you? The story starts before your stating 
of the facts you would like us to believe. The story starts with putting 
resellers and so-called RAs in charge of validation procedures they have 
no clue about and with failing to audit, approving and controlling them, 
it's called due diligence. The story continues with failing to prevent 
issuance of high-profile target certificates such as Mozilla certainly 
is and the story continues with failing to detect them once issued. As I 
said, you are only seeing the tail...




There seems to be an emerging consensus that more open is more better,
in general at least.



This might be correct. However generally speaking CP and CP statements, 
other documents publicly available in addition to general questioning 
(at least during our review procedures at Mozilla) are fairly sufficient.


In relation to Comodo, the writing has been on the wall.


E.g., where Comodo or any CA completes an internal audit and creates a
report to document that audit action, could we expect the CA or the
internal auditor to publish this as a routine action?



I don't think we can expect that as a general role.

--
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Signer: Eddy Nigg, StartCom Ltd.
Jabber: start...@startcom.org
Blog:   https://blog.startcom.org
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Re: Unbelievable!

2008-12-26 Thread Nelson B Bolyard
ro...@comodo.com wrote, On 2008-12-26 03:28:

We have finished our initial investigation on the certificates
 issued by Certstar.
 
 Of the 111 orders that had been placed through Certstar there remain
 13 orders for which we have still not been able to gather adequate
 evidence of the applicant having domain control.  We have therefore,
 regrettably, revoked the certificates on those orders.
 
 Of those 13 orders, 2 were placed by Eddy, for startcom.org and
 www.mozilla.com, as he has already described.  As we previously
 stated, the certificate for www.mozilla.com was revoked shortly after
 it was issued.
 
 Of the remaining 11 orders we do not have any reason to believe that
 any were placed fraudulently and had we not set such a short timescale
 to effect the (re-)validation and had it not been over this Holiday
 season we believe that we would have been able to achieve validation
 of domain control for all 11.
 
 Certstar have passed to us all of their records for these customers
 and we will ensure that they are contacted for 2 purposes:
 a) to check if it would have been possible to complete the re-validation
 b) to offer a replacement certificate.
 Some of the orders have either been charged-back or refunded.  We have
 to accept the possibility that some of those customers will not assist
 us in re-validation.
 
 Regards
 Robin Alden
 Comodo

Robin,  Thanks for that report.

Speaking for myself only, I think that the speed with which you and Comodo
dealt with this issue, once it became publicly known, and the integrity
you  Comodo showed by revoking 11 certs (~10%) whose veracity simply could
not be determined in a timely fashion, is commendable.

Issues remain, and will continue to be discussed about how this situation
came to be, and what new measures should be taken, and by whom, to minimize
the probability of it ever happening again.  But one clear conclusion from
this episode is that there is not a single clear line of separation of
responsibilities between CAs and RAs that applies to all CAs.  Clearly
several participants in this discussion were surprised that a CA would
delegate the duty of validating domain control to an RA, and some opined
that a CA ought to perform that duty itself.  I'm not convinced that's
necessary, but it certainly does seem that a CA firm ought to be prepared
to deal with the possibility that an RA makes a (potentially big) mistake
without sacrificing the CA firm's entire business.  The challenge, in the
event of an RA error, is to restore/maintain confidence in the integrity
of the CA's PKI overall, while mitigating the potential damage from dubious
enrollments.

In this case, it was feasible to examine the data for ~90% of the RA's 111
enrollments in a reasonably short time.  If the RA had enrolled 10 or 100
times as many, a much larger number (and probably a larger percentage) of
the enrollments might not have been verifiable in such a short time.
I wonder if it would have been perceived as feasible to revoke all the
unverified certs in such a case, and still remain in business.

I personally received numerous requests (mostly privately) asking for ways
for browser users to effectively disable the trust for the certs issued
under the auspices of this particular RA, at least until the veracity of
those certs could be sorted out.  As you and I discussed in bug 470897, the
only options available to users, which would effectively distrust the entire
PositiveSSL CA cert (or the entire root with all its subordinate CAs), would
have also effectively distrusted the certs issued under the auspices of
numerous other RAs.  Hence that solution would not have been a good fit for
the scope of the problem.  Nevertheless, a number of people
expressed to me the view that disabling trust in the subordinate CA that
issued certs for that RA, while too broad of a measure, was nonetheless
preferable to leaving themselves vulnerable to the possibility of false
certificates.  I sensed that they wanted the ability to take action that fit
the scope of the potential problem well, and also was potentially
reversible if and when things were finally sorted out (as it now seems they
are).  Had there been a separate CA issuing certs for this RA, the ability
to disable trust for that CA cert and the ability to restore that trust
at a later time (such as now) would have been much more satisfying to many,
I believe.

So, I would like to suggest that Comodo consider modifying its practices
somewhat, to reduce the mismatch of scope between subordinate CAs and RAs.
I suggest that Comodo operate a separate subordinate CA for each RA to
whom Comodo has delegated validation duties.  I suggest that a new
subordinate CA be created for each such RA, and that all new certs issued
for those RAs be issued from those new single-RA CAs.  I am aware of at
least one other commercial CA that operates that way, operating a separate
subordinate CA for each RA to whom they have delegated validation duties.
I 

Re: Unbelievable!

2008-12-26 Thread Kyle Hamilton
I am minded of the CRL entry reason remove from CRL.  Does NSS
properly handle that reason-code?

If so, a temporary revocation of all unknown certificates might be a
sound practice, removing them from the CRL as they're found and
verified.

We are running up against problems that are caused by absolute
adherence to inflexible standards, and we're proposing mechanisms
inside of the inflexible standards to deal with them.

If there were a way to, say, have the CA include a unique, opaque code
for the RA that submitted a CSR in the issued certificate, AND if
there were a way to filter based on the content of an extension
(rather than simply leaving it completely opaque, which leads to the
current problem), then there would be no need for a separate CA for
each RA.

-Kyle H

On Fri, Dec 26, 2008 at 5:38 PM, Nelson B Bolyard nel...@bolyard.me wrote:
 ro...@comodo.com wrote, On 2008-12-26 03:28:

We have finished our initial investigation on the certificates
 issued by Certstar.

 Of the 111 orders that had been placed through Certstar there remain
 13 orders for which we have still not been able to gather adequate
 evidence of the applicant having domain control.  We have therefore,
 regrettably, revoked the certificates on those orders.

 Of those 13 orders, 2 were placed by Eddy, for startcom.org and
 www.mozilla.com, as he has already described.  As we previously
 stated, the certificate for www.mozilla.com was revoked shortly after
 it was issued.

 Of the remaining 11 orders we do not have any reason to believe that
 any were placed fraudulently and had we not set such a short timescale
 to effect the (re-)validation and had it not been over this Holiday
 season we believe that we would have been able to achieve validation
 of domain control for all 11.

 Certstar have passed to us all of their records for these customers
 and we will ensure that they are contacted for 2 purposes:
 a) to check if it would have been possible to complete the re-validation
 b) to offer a replacement certificate.
 Some of the orders have either been charged-back or refunded.  We have
 to accept the possibility that some of those customers will not assist
 us in re-validation.

 Regards
 Robin Alden
 Comodo

 Robin,  Thanks for that report.

 Speaking for myself only, I think that the speed with which you and Comodo
 dealt with this issue, once it became publicly known, and the integrity
 you  Comodo showed by revoking 11 certs (~10%) whose veracity simply could
 not be determined in a timely fashion, is commendable.

 Issues remain, and will continue to be discussed about how this situation
 came to be, and what new measures should be taken, and by whom, to minimize
 the probability of it ever happening again.  But one clear conclusion from
 this episode is that there is not a single clear line of separation of
 responsibilities between CAs and RAs that applies to all CAs.  Clearly
 several participants in this discussion were surprised that a CA would
 delegate the duty of validating domain control to an RA, and some opined
 that a CA ought to perform that duty itself.  I'm not convinced that's
 necessary, but it certainly does seem that a CA firm ought to be prepared
 to deal with the possibility that an RA makes a (potentially big) mistake
 without sacrificing the CA firm's entire business.  The challenge, in the
 event of an RA error, is to restore/maintain confidence in the integrity
 of the CA's PKI overall, while mitigating the potential damage from dubious
 enrollments.

 In this case, it was feasible to examine the data for ~90% of the RA's 111
 enrollments in a reasonably short time.  If the RA had enrolled 10 or 100
 times as many, a much larger number (and probably a larger percentage) of
 the enrollments might not have been verifiable in such a short time.
 I wonder if it would have been perceived as feasible to revoke all the
 unverified certs in such a case, and still remain in business.

 I personally received numerous requests (mostly privately) asking for ways
 for browser users to effectively disable the trust for the certs issued
 under the auspices of this particular RA, at least until the veracity of
 those certs could be sorted out.  As you and I discussed in bug 470897, the
 only options available to users, which would effectively distrust the entire
 PositiveSSL CA cert (or the entire root with all its subordinate CAs), would
 have also effectively distrusted the certs issued under the auspices of
 numerous other RAs.  Hence that solution would not have been a good fit for
 the scope of the problem.  Nevertheless, a number of people
 expressed to me the view that disabling trust in the subordinate CA that
 issued certs for that RA, while too broad of a measure, was nonetheless
 preferable to leaving themselves vulnerable to the possibility of false
 certificates.  I sensed that they wanted the ability to take action that fit
 the scope of the potential problem well, and also was potentially
 

Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread Nelson B Bolyard
patri...@certstar.com wrote, On 2008-12-26 14:52:

 Lately we have all seems that the certificate system is not 100%
 secure - mistakes happen. It might never become fully bullet proof but
 one simple change might help a lot.
 
 How about creating certificate type that is registered in a central
 database and require all CAs to check this DB before issuing new
 certificates? Once in that database no certificates could be issued
 for this specific domain. I think that most high profile sites would
 take advantage of such service.

I think you're suggesting a cooperative agreement among CAs, whereby
once a cert was issued for a domain name by one CA, other cooperating
CAs would refuse to issue a cert for that same domain name.
Is that what you're suggesting?

Assuming that it is, here are some questions and observations.

1) What problem would this proposed central database solve?  Would it
exist merely to keep CAs from inadvertently soliciting the customers of
their competitors?  What other purpose, if any, would it achieve?

2) Would this lock a cert customer into a single vendor?  Would it
prevent a party from enrolling for certs from several different CAs?
As an acquirer of certificates, I would not want to be locked in to
a single CA.

3) If some CAs agree to such an approach, and others do not, is it still
valuable?

4) I think this database effectively exists already, albeit in a
distributed (not centralized) fashion.  If you want to know if the server
at a certain DNS name already has a cert, and who issued it, and when it
is due to expire, you can simply visit that server with an SSL client
on any (or all) of the usual SSL ports (443, 465, 993), get the server's
current cert, and get all that information from it.  I suspect you know
this already.  :)

5) There is an organization of cooperating CAs and browser makers,
known as the CA-Browser Forum (CABForum.org), the people behind EV.
They're probably the group to which proposals for CA cooperation
should be directed.  They only admit CAs, and as Certstar is an RA,
I'm not sure you could become a member.  But Comodo could represent you,
or perhaps invite you to participate in the mailing list.  And you can
always send email to the email address on their web site.
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Re: Facts about Comodo Resellers and RAs

2008-12-26 Thread Eddy Nigg

Comodo's CPS [1]  lists the following:

1.10.2 Web Host Reseller Partners

Through a “front-end” referred to as the “Management Area”, the Web Host 
*Reseller* Partner has access to the *RA* functionality including but 
not limited to the issuance of Secure Server Certificates  is 
obliged to *conduct validation* in accordance with the validation 
guidelines and agrees via an online process (checking the “I have 
sufficiently validated this application” checkbox when applying for a 
Certificate) that sufficient validation has taken place prior to issuing 
a certificate.


This seems to be exactly in line with my comment [2] and the published 
image [3]. If this is correct, than it is in direct conflict with 
section 4.2.7 PositiveSSL and PositiveSSL Wildcard Secure Server 
Certificates of this statement [4]:


To validate PositiveSSL and PositiveSSL Wildcard Secure Server 
Certificates, *Comodo* checks that the Subscriber has control.

and the use of generic e-mails which ordinarily are only
available to person(s) controlling the domain name administration, for 
example, webmaster@ . . ., postmaster@ . . ., admin@;



This basically means that Comodo outsources domain validation not only 
to RAs but also to resellers. In addition, domain validation is 
effectively circumvented and non-existent for such resellers. The mere 
checking of the checkbox is the only requirement for the issuance of any 
certificate. This is in my opinion insufficient and and undue risk! 
Considering the size of Comodo's reseller and RA network (which I'm sure 
makes up the biggest junk of their certificates issuance), it is 
reasonable to assume that unvalidated certificates exist currently.


Additionally I want to point out that the CPS [4] explicitly states that 
Comodo performs the validation, which however is not the case as we've 
seen with certstar. Since I was reading this document during the review 
period of Comodo this spring, I was fairly convinced that Comodo 
performs those validations.


I request to receive further information about how exactly domain 
control is validated and which controls Comodo has in place to prevent 
fraudulent or mistaken issuance. Incidentally I've found discrepancy in 
statements made by Robin as to the status of certstar in particular and 
concerning domain validation in general.



[1] 
http://www.comodo.com/repository/09_22_2006_Certification_Practice_Statement_v.3.0.pdf

[2] https://bugzilla.mozilla.org/show_bug.cgi?id=470897#c27
[3] https://bugzilla.mozilla.org/attachment.cgi?id=354425
[4] 
http://www.comodo.com/repository/PositiveSSL_addendum_to_the_Certification_Practice_Statement.pdf


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Re: Unbelievable!

2008-12-26 Thread Paul C. Bryan
On Dec 26, 5:38 pm, Nelson B Bolyard nel...@bolyard.me wrote:

 Clearly several participants in this discussion were surprised that a CA would
 delegate the duty of validating domain control to an RA, and some opined
 that a CA ought to perform that duty itself.

I certainly fall in that category.

 I'm not convinced that's necessary, but it certainly does seem that a CA firm
 ought to be prepared to deal with the possibility that an RA makes a 
 (potentially
 big) mistake without sacrificing the CA firm's entire business. The 
 challenge, in
 the event of an RA error, is to restore/maintain confidence in the integrity
 of the CA's PKI overall, while mitigating the potential damage from dubious
 enrollments.

I think I can boil down my concern in this statement:

When trust is being established in a certification authority, trust is
explicitly being placed in its operational practices. It is not being
trusted in its ability to place trust in turn in whomever it may
decide to outsource its operations. By allowing arbitrary parties to
perform critical RA activities (such as DV) the CA is attempting to
extend its operations beyond that which was originally judged.

 So, I would like to suggest that Comodo consider modifying its practices
 somewhat, to reduce the mismatch of scope between subordinate CAs and RAs.
 I suggest that Comodo operate a separate subordinate CA for each RA to
 whom Comodo has delegated validation duties.  I suggest that a new
 subordinate CA be created for each such RA, and that all new certs issued
 for those RAs be issued from those new single-RA CAs.  I am aware of at
 least one other commercial CA that operates that way, operating a separate
 subordinate CA for each RA to whom they have delegated validation duties.
 I believe that is a sound way to minimize the collateral damage that
 might need to be inflicted, even temporarily, to restore/maintain PKI
 integrity in the event of a breach.

I believe your suggestion is valid. This seems to fit s. 13 of the
Mozilla CA Certificate policy: ... we recommend that CAs consider
using separate root CA certificates with separate public keys (or
separate intermediate CA certificates with separate public keys under
a single root) when issuing certificates according to different
Certificate Policies, so that we or others may selectively enable or
disable acceptance of certificates issued according to a particular
policy, or may otherwise treat such certificates differently ...

I believe another valid option would be for the CA to incorporate key
RA duties, namely domain verification. The CA can still have resellers
that initiate registration and collect information. Verification would
remain within the operations of that which is judged in the CA's
conformance to policy.
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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread Eddy Nigg

On 12/27/2008 04:10 AM, Kyle Hamilton:

I note that the WebTrust audit seal that Robin provided links to only
mentions auditing in relation to EV certificate issuance, and does not
address anything at all outside of that scope.

This report does not include any representation as to the quality of
Comodo's services beyond those covered by the WebTrust for
Certification Authorities EV Criteria, nor the suitability of any of
Comodo's services for any customer's intended purpose.

i.e., there is no audit for non-EV certificate issuance, and thus
non-EV certificate issuance has no reason at all to be trusted.

This is problematic.



Right, there must be another report for regular WebTrust somewhere.


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Re: Avoid incorrect issuing of Certificates

2008-12-26 Thread Nelson B Bolyard
Kyle Hamilton wrote, On 2008-12-26 18:10 PST:
 I note that the WebTrust audit seal that Robin provided links to only
 mentions auditing in relation to EV certificate issuance, and does not
 address anything at all outside of that scope.

Here are some Comodo seal numbers that I found:
 212 537 636 798 804
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