[cabf_validation] Ballot 190 Section 2

Mon Apr 24 12:18:08 MST 2017

Sorry - I was mistaken.  The ballot language does specify that the reuse is
limited to 825 days.

“This provisions of Ballot Section 1 will apply only to the validation of
domain names occurring after this Ballot 190’s effective date.  Validation
of domain names that occurs before this Ballot’s effective date and the
resulting validation data may continue to be used for the periods specified
in BR 4.2.1 and EVGL 11.14.3 so long as the validations were conducted in
compliance with the BR Section 3.2.2.4 validation methods in effect at the
time of each validation.”

This means we just need to add this language to the BRs and reference it in
the EV Guidelines.

From: Kirk Hall [mailto:Kirk.Hall at entrustdatacard.com]
Sent: Monday, April 24, 2017 1:15 PM
To: Jeremy Rowley <jeremy.rowley at digicert.com>; CA/Browser Forum Validation
WG List <validation at cabforum.org>
Subject: RE: Ballot 190 Section 2

Can you explain your last sentence - not clear to me.  What BR and EVGL
section(s) are you referring to?

From: Jeremy Rowley [mailto:jeremy.rowley at digicert.com]
Sent: Monday, April 24, 2017 12:04 PM
To: CA/Browser Forum Validation WG List <validation at cabforum.org
<mailto:validation at cabforum.org> >
Cc: Kirk Hall <Kirk.Hall at entrustdatacard.com
<mailto:Kirk.Hall at entrustdatacard.com> >
Subject: RE: Ballot 190 Section 2

That is my understanding of Google’s position. However, he wasn’t wrong
that the proposed language would permit unlimited reuse for longer lived
certificates.

From: Validation [mailto:validation-bounces at cabforum.org] On Behalf Of Kirk
Hall via Validation
Sent: Monday, April 24, 2017 12:57 PM
To: CA/Browser Forum Validation WG List <validation at cabforum.org
<mailto:validation at cabforum.org> >
Cc: Kirk Hall <Kirk.Hall at entrustdatacard.com
<mailto:Kirk.Hall at entrustdatacard.com> >
Subject: Re: [cabf_validation] Ballot 190 Section 2

If I understand correctly, Google wants all domain validation data that was
based on prior validation methods 1-7 (even if properly executed) to be
discarded, even if the resulting validation data is still within the
permitted data reuse period, if the domain validation was based on any
validation procedure that was changed by Ballot 169 (now, Ballot 190).

All such domains would have to be re-validated immediately using the changed
methods as specified in Ballot 190.

Mozilla pointed out on the last Forum call that taking this position (and
not allowing prior domain validation data to be reused according to our
reuse of data rules until the data expires) will be a big disincentive for
CAs to ever vote for incremental changes to validation methods - if it means
that CAs are suddenly required to revalidate thousands of domains all at
once (even domains that were properly validated under old rules the day
before the new rules take effect), CAs won’t want to vote for that unless
there is a showing of a some serious and widespread security issue affecting
the prior validations.

I think the new rules of Ballot 190 should only apply to new domain
validations that occur after Ballot 190 is approved and becomes effective.
The only argument I heard about past deficiencies in validation related to
(new and improved) BR 3.2.2.4.6- Agreed-Upon Change to Website (i.e., there
was an argument that some past validations were not correct in some way) -
but I don’t think we received any details, examples, or numbers.  Old
method 6 stated “Having the Applicant demonstrate practical control over
the FQDN by making an agreed‐upon change to information found on an online
Web page identified by a uniform resource identifier containing the FQDN.”
We are not aware of any problems for past validations we have done using
this method.

One problem with discarding all or most prior domain validation data is - we
have no automated way of knowing which domains were validated using
particular methods - so if Ballot 190 says (for example) that  domains
verified using the prior Agreed Change to Website method have to be
revalidated (but no other methods), we would have to manually review ALL our
past domain validations to find which were done using this method - again, a
major task, and not something we want to do unless there is evidence
presented that these past domain validations have lots of serious problems.

That’s why Section 2 was included in Ballot 190 - to make these changed to
domain validations apply only to new validations occurring after the ballot
effective date.  I think that is how we have handled incremental changes to
validation methods in the past, and I still think that’s the best approach.

From: Validation [mailto:validation-bounces at cabforum.org] On Behalf Of Doug
Beattie via Validation
Sent: Monday, April 24, 2017 11:35 AM
To: CA/Browser Forum Validation WG List <validation at cabforum.org
<mailto:validation at cabforum.org> >
Cc: Doug Beattie <doug.beattie at globalsign.com
<mailto:doug.beattie at globalsign.com> >
Subject: [EXTERNAL]Re: [cabf_validation] Ballot 190 Section 2

The “any other method”  still remains as a valid option and the problem
outlined below is only when this method is removed, correct?  We basically
need to grandfather in validation data collected under method 11 for some
period of time.  Ryan does not want this to be 39 months for all the reasons
he listed.

Is that the crux of the issue?

Doug

From: Validation [mailto:validation-bounces at cabforum.org] On Behalf Of
Jeremy Rowley via Validation
Sent: Monday, April 24, 2017 1:37 PM
To: CA/Browser Forum Validation WG List <validation at cabforum.org
<mailto:validation at cabforum.org> >
Cc: Jeremy Rowley <jeremy.rowley at digicert.com
<mailto:jeremy.rowley at digicert.com> >
Subject: [cabf_validation] Ballot 190 Section 2

Section 190 was withdrawn because of objections to Section 2 of the ballot:

“This provisions of Ballot Section 1 will apply only to the validation of
domain names occurring after this Ballot 190’s effective date.  Validation
of domain names that occurs before this Ballot’s effective date and the
resulting validation data may continue to be used for the periods specified
in BR 4.2.1 and EVGL 11.14.3 so long as the validations were conducted in
compliance with the BR Section 3.2.2.4 validation methods in effect at the
time of each validation.”

Basically, the browsers would like a date when this cuts off so that old
certificate validation data can’t be reused. Any thoughts on how to
reconcile?

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