[cabf_validation] Amend BR subsections 7.1.4.2.2 d/e

Fri Jun 3 04:12:05 MST 2016

To summarize, you’re saying you must have Country and Organization and that you must have stateOrProvinceName and/or localityName unless < you reason>, in which case both stateOrProvinceName and localityName can be omitted.

Where <your reason> is: The country/jurisdiction specified by the subject:countryName field has a centralized registry for that kind of organizations so that the organization name specified by the subject:organizationName field is "unique" in the entire country/jurisdiction

You have one small copy/past issue in your recommendation, but I understand what you meant.

During the call yesterday we also discussed listing all of the countries where this is the case.  You listed about 31 countries with no stateOrProvinceName, but it’s not clear which of these also have no localityName, just the 3 in red?   I still think it would be a good idea to enumerate the entire list of Country codes where both stateOrProvinceName and localityName can be omitted so there is no confusion and compliance can be monitored.

Doug

From: validation-bounces at cabforum.org [mailto:validation-bounces at cabforum.org] On Behalf Of ???
Sent: Friday, June 3, 2016 6:56 AM
To: 'Rick Andrews' <Rick_Andrews at symantec.com>; 'Jeremy Rowley' <jeremy.rowley at digicert.com>; validation at cabforum.org; Peter Bowen <pzb at amzn.com>; 'Rob Stradling' <rob.stradling at comodo.com>; policyreview at cabforum.org
Cc: Dean Coclin <Dean_Coclin at symantec.com>; 王文正 <wcwang at cht.com.tw>; Kirk Hall <Kirk.Hall at entrust.com>
Subject: [cabf_validation] Amend BR subsections 7.1.4.2.2 d/e

Dear All,

     As yesterday’s validation working group phone call discussion about DN in small countries such as Singapore and Taiwan. I resend some discussions after Certificate Policy working group mailing list  phone call, Bugzilla and discussion in 33rd F2F meeting (as attached file) as below.
After  discussions, we will write a pre-ballot to fix the issue.

     We suggest to amend BR 7.1.4.2.2 d/e.

Li-Chun CHEN<mailto:lcchen.cissp at gmail.com> 2016-02-05 01:29:17 MST
After discussion in Chunghwa Telecom, Dr. Wen-Cheng Wang suggests to amend subsections 7.1.4.2.2 d/e as below:

d.    Certificate Field: subject:localityName (OID: 2.5.4.7)
Required if the subject:organizationName field is present and the subject:stateOrProvinceName field is absent.
Optional if: (a) the subject:organizationName and subject:stateOrProvinceName fields are present, or (b) if the
subject:organizationName and subject:countryName fields are present and the country/jurisdiction specified by the
subject:countryName field has a centralized registry for that kind of organizations so that the
organization name specified by the subject:organizationName field is "unique" in the entire country/jurisdiction.
Normally, situation (b) may exist in small countries/jurisdictions such as Singapore (SG), Taiwan (TW), etc.

e.    Certificate Field: subject:stateOrProvinceName (OID: 2.5.4.8)
Required if the subject:organizationName field is present and subject:localityName field is absent.
Optional if: (a) the subject:organizationName and subject:stateOrProvinceName fields are present, or (b) if the
subject:organizationName and subject:countryName fields are present and the country/jurisdiction specified by the
subject:countryName field has a centralized registry for that kind of organizations so that the
organization name specified by the subject:organizationName field is "unique" in the entire country/jurisdiction.
Normally, situation (b) may exist in small countries/jurisdictions such as Singapore (SG), Taiwan (TW), etc.

      As for Peter, he e-mailed that
I think there is a misunderstanding.  The address represented in the certificate by the plain localityName and stateOrProvinceName attributes is the Applicant’s address of existence or operation, not their jurisdiction of incorporation.  The BRs note that a utility bill or bank statement can be used to verify the address.

For example, https://crt.sh/?id=11206357&opt=cablint shows that the FQDN is www.fenton.com.tw<http://www.fenton.com.tw>. The contact information provided on the website (http://www.fenton.com.tw/index.php?route=information/contact) is 高雄市新興區民權一路251號24樓之2.  Assuming you verify that this is the address of the applicant, then you could include 高雄市 (or Kaohsiung) in the localityName or stateOrProvinceName field.

I don’t think there is any need to update the BRs for this case.

      But I have to say that  高雄市 (or Kaohsiung) should be  in the localityName field. There is no State or Province in Taiwan for高雄市(or Kaohsiung).

     And Dr. Wen-Cheng Wang has replied to Peter as below:

   We know that the current BR tends to interpret the localityName and stateOrProvinceName attributes as identifying the subject’s address of existence or operation. However, to enforce this kind of interpretation and require the Subject DN must at least contain either the localityName and stateOrProvinceName attributes may cause problem in some situations, especially in some small country where organizations are allowed to be registered at country-level. For example, in Taiwan, a corporation can be registered at country-level but can also be register at city/county-level. If there is a country-level corporation named “Farmer’s Association” of which physical address is located in Taipei City, with current Subject DN rule of BR, its Subject DN will be “C=TW, L=Taipei City, O=Farmer’s Association”. However, if there is also a city/county-level “Farmer’s Association” in Taipei City, its Subject DN will also be “C=TW, L=Taipei City, O=Farmer’s Association”. How do you distinguish them by DN?

I do not understand why we need to enforce require the Subject DN must at least contain either the localityName and stateOrProvinceName attributes if the registered organizational name of a country-level corporation/organization is already guaranteed to be unique under the country name?

The following diagram is taken from Annex B of ITU-T X.521 (Suggested name form and Directory information tree structures). Please note path 1 -> 3, it suggests that there is no need to include a Locality attribute in the directory name of a country-level organization.
[cid:image001.png at 01D169D3.5ED33150]

Sincerely Yours,

        Li-Chun CHEN
        Chunghwa Telecom Co. Ltd.

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