Hi Mike, We still think that the questions are not relevant for the process of root inclusion, but we are happy to assist. Nevertheless, we would like to make our holistic answers as comprehensive and clear as possible in order to maximise transparency. We would like to express again that we fulfil all applicable requirements and will continue to do so in the future.
Does D-Trust hold the position that reduction of certificate duration by a root program is anti-competitive? We consider, a reduction in the certificate duration is not inherently anti-competitive. According to our position, the implications of such a reduction depend significantly on how it is introduced or enforced by market participants who hold market-dominant positions. If these participants leverage their influence in ways that restrict competition or create unfair advantages for themselves, this may certainly lead to anti-competitive practices. In procedures in which the interests of all market participants and the web security are sufficiently taken into account, we see no anti-competitive problems. Does D-Trust hold the position that reduction of certificate validity has negative impact on the security of the web PKI? We cannot answer this question with a clear yes or no, as the answer depends heavily on the specific circumstances of the introduction and subsequent implementation of the reduction of certificate validity. According to our opinion, factors such as the context in which the measure is implemented, the actors involved, the resources and the general framework conditions may play a decisive role and have a significant influence on the results. Does D-Trust hold the position that browser market share is relevant to determining the validity or importance of root program positions on matters of web PKI policy? Every relevant root program policy is important to us and is given equal importance. From our perspective, it needs neutral and unambiguous position. Does D-Trust hold the position that “roll-over” requests are or should be subject to less scrutiny than those of initial inclusion? D-Trust has understood from previous and current discussions that there is a strong desire among some root store operators to shorten the duration of root and SubCA certificates. Currently, root certificates are designed to be used over a longer period of 10 to 15 years. Experience shows that the root inclusion process takes between one and four years for all relevant root store operators. It is currently not possible to estimate the exact duration in advance. Our understanding is that if root and subCA certificates are to have significantly shorter durations in the future to promote agility in cryptography, an optimised onboarding process is required. We welcome and understand that a very thorough review of the requesting TSP and the corresponding root certificates is necessary for the initial integration. However, we are of the opinion that the renewal of an already included root does not necessarily require an examination comparable or equal to that of an initial inclusion. The TSP and the already included roots are already subject to a strict governance regime, which ensures that the security and reliability requirements are continuously met. In addition, an application for root inclusion is only submitted to the CCADB community once it has been proven that all requirements have been met. This procedure should enable a more efficient and faster integration of root certificates in the future and at the same time ensure the necessary security and trustworthiness. We are convinced that adapting the integration process will not only improve the competitiveness, but also promote innovation in the field of publically trusted certificates. Thanks, Enrico ________________________________ Von: public@ccadb.org <public@ccadb.org> im Auftrag von Mike Shaver <mike.sha...@gmail.com> Gesendet: Samstag, 19. Oktober 2024 15:30 An: Ryan Dickson <ryandick...@google.com> Cc: public <public@ccadb.org> Betreff: Re: Public Discussion of D-Trust TLS CA Inclusion Request As promised, here are my outstanding unanswered questions about D-Trust’s position on PKI-related matters: - does D-Trust hold the position that reduction of certificate duration by a root program is anti-competitive? - does D-Trust hold the position that reduction of certificate validity has negative impact on the security of the web PKI? - does D-Trust hold the position that browser market share is relevant to determining the validity or importance of root program positions on matters of web PKI policy? - does D-Trust hold the position that “roll-over” requests are or should be subject to less scrutiny than those of initial inclusion? I would appreciate D-Trust’s responsive replies to these questions, in the absence of cogent explanation for why these questions are not suitable as part of discussion of a root’s application for (continued) inclusion. I would also appreciate the perspective of other members of this community on the relevance of the questions, as I hold the position that they will be relevant to future inclusion discussions as well. Mike -- You received this message because you are subscribed to the Google Groups "CCADB Public" group. To unsubscribe from this group and stop receiving emails from it, send an email to public+unsubscr...@ccadb.org<mailto:public+unsubscr...@ccadb.org>. 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