[cabf_validation] Using 3.2.2.4.2/.3 for future domains

[Peter Bowen]

> On Mar 17, 2018, at 7:43 AM, Ryan Sleevi <sleevi at google.com> wrote:
> 
> 
> 
> On Fri, Mar 16, 2018 at 4:11 PM, Peter Bowen <pzb at amzn.com <mailto:pzb at amzn.com>> wrote:
> 
> I wasn’t asking about validation methods, I was asking about delegation of rights.  When a corporation appoints an officer (who can sign for the company, or put another way has a delegation from the corporation), it is persistent.  If I give someone power of attorney for financial matters, it isn’t only valid for bank accounts which existed at the time the PoA was signed.   If someone has the right to sell a domain, cancel a domain, or transfer a domain (all things which can be done by delegating the right to manage any domain with a given registrant entity), why should they not have the right to approve certificates for the domain?
> 
> I understand the appeal of the analogy, but it's not entirely apt. As described, this is the notion of someone granting themselves PoA (and without necessarily even having to disclose this) in perpetuity.

No, this is Person A granting Person B power of attorney.  Or it is Example Corp appointing Person B as an officer of Example Corp.  I am not a lawyer, but to my knowledge these are generally done in perpetuity and are not publicly disclosed.  

> Fundamentally, this is a problem with an 'ownership' model of domains, as it attempts to intentionally evade the notion of whether the Applicant Representative is authorized. The discussions during the F2F were very illustrative of this, and the creativity CAs apply to try to reach the Applicant and allow the Applicant to self-attest their authorization.
> 
> Let's set aside the ownership question for a second, though, because it's clear that how CAs have interpreted "domain ownership" is fundamentally at odds with a basic level of security - both for users and "victim" domain holders (even if it helps a subset of domain holders). 

I’m confused by this statement.  The BRs require that the CA verify that the "Applicant had the right to use the Domain Name(s)”.  The strongest evidence of right to use would appear to be that the domain owner/holder/registrant, or their delegated representative, explicitly indicates the applicant as the right to use.  Do you disagree?

> Consider the use of .7, in which we already permit (by virtue of CNAME) an expression of delegation to a separate entity via DNS. If the entire concern is that the respondant in WHOIS is not the PKI approver (preventing .2 and .3), and that the domain operator "for reasons" cannot configure one of the mailboxes (.4), would the expression of a domain record that allowed for a designated approver suffice? This could be established for all new/additional domains, can be verified technically, can be checked, and is "no worse" than setting a mailbox under .2/.4 or a CNAME under .7 to delegate to a PKI approver. Does this meet the needs?
> 
> Or consider during the F2F, there was a discussion of expanding .12 in a way that the DNS Owner could put in a "challenge token" (of sorts) into WHOIS, which allowed them to uniquely and unambiguously link back to the notion of a CA account. Would such a link - in which the CA validated the existence (under the proposed ".13" rules, to be fleshed out) of this random token - suitably replace the need to do an organization-identity link? I think so.
> 
> However, if the proposal of the .1 supporters is that they should not have to consult DNS to verify an explicit authorization to delegate - such as a DNS record or (additional) WHOIS configuration - and instead rely on the mere existence of information that ICANN requires of domain holders - then that will remain unacceptable, as it's a fundamentally weak proposition.

I cannot speak for others, but my assertion is that the BRs are clear.  The Applicant needs _either_ “control” or “right to use” (see §9.6.1(1) ).  The latter is a legal concept.  Are you suggesting that the BRs should be changed to require control (and potentially make it clear that control is the only test; the certificate does not assert that it is authorized control)?

Thanks,
Peter

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