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RE: A Response to the Microsoft Letter ...

2004-11-09 13:31:12
Some of the content of this letter is beyond me.  Too bad for me.
But I agree with the parts that I do understand.
How can I have my name added to the letter?
Or should I send my own copy?  If so, does anyone have a list of email
addresses to send this letter?

For the record, my biggest problem is the license requirement.  I am for
open source, and open standards.  If email (SMTP) was a new protocol, then
fine, someone can own it.  But SMTP has been around for well over 15 years,
and it has been an open standard used world wide.  No new standard, built on
SMTP should be allowed to risk the world wide SMTP network.

"Another concern is that some of these schemes are subject
to intellectual property right claims. To ensure wide
spread deployment and an equal playing field, we would urge
that any licenses be royalty free and fully compliant with
the Open Standards Alliance model."

Thanks,
Guy Watkins


-----Original Message-----
From: owner-spf-discuss(_at_)v2(_dot_)listbox(_dot_)com
[mailto:owner-spf-discuss(_at_)v2(_dot_)listbox(_dot_)com] On Behalf Of John 
Glube
Sent: Tuesday, November 09, 2004 1:13 PM
To: spf-discuss(_at_)v2(_dot_)listbox(_dot_)com
Subject: RE: [spf-discuss] A Response to the Microsoft Letter ...

Folks,

As people may or may not know on Friday, a letter was
delivered to the FTC Commissioners and the Director of NIST
on behalf of 30 signatories, including Microsoft.

http://www.truste.org/pdf/Sender_ID_FTC_Letter.pdf

In essence this letter calls for adaptation of SIDF today.

Follows is a draft of a letter that people may wish to use
as a basis for a response.

A quick bit of background. This draft is taken from a
submission made on Monday by a group participating in the
summit to the FTC. 

The original letter was written by me and I received
permission to use the letter as support for this draft
should people wish to use it.

Yesterday, and earlier today I ran the draft under a nose
or two and received some feedback for which I am grateful.

Based on this feedback, while folks are going through the
nomination process, I thought this letter might help give
people some food for thought and should the new SPF
community wish to adopt it either as is or modified and
forward it on, hey - go for it.

I am concerned that all the "politicking" which has been
going on involving Microsoft is distracting folks from the
task at hand.

To the best of my understanding MS wants PRA because its
financial clients want "something" to stop "phishing." The
immediate solution? Come up with a "security" icon for
email at the MUA level and PRA is designed to set this up. 

This is akin to the MS "security" icon on its software. A
lot of folks feel that the use of PRA checking to support
this approach is an anathema or worse.

Some people like mfrom because it works for the way much of
email is sent.

Meng wants to move ahead with coding for SRS along with
implementation of various patches, so that the whole thing
for mfrom is "plug 'n play."

Others feel this is the wrong way and prefer SES. 

Others prefer ehelo/helo + a "white list" as it allows for
end to end validation of the mail channel and is much
simpler to implement.

(As an aside, it does not have to be a "white" list. It
could be a list with a point score applied to each
registrant which could be plugged into real time reputation
data and used for filtering purposes by the end user.)

The problem? What ever is going to work, we need to stay
focused on the goals. 

At the same time, we don't have enough data to sort out
what will, or won't truly work all the way from small
systems to large scale systems like those used by AOL and
even larger.

In addition, many people feel MS has made things awkward by
calling upon folks to sign a patent license which creates
some friction.

What do we want to achieve?

To develop and implement a workable system for IP/Domain
based sender (aka mail channel) and message
authentication that can work in real time with
accreditation (reputation) services across all range of
situations from the web host with a single dedicated server
with secure log in and a few hosted clients who send email
through a shared server to the largest mailing systems in
the world.

The focus of SPF has been to develop a record syntax, based
on a multitude of potential uses along with patches to
allow for servers to authenticate senders by extracting the
FQDN in mfrom and depending on which specification one
relies upon, in its absence the FQDN in the EHELO/HELO and
check to see whether the IP address of the client server is
authorized to send mail for this domain.

With that being said, follows is the draft

November 15, 2004

Chairperson Deborah Platt Majoras
Federal Trade Commission
Room 440
600 Pennsylvania Ave, NW
Washington, DC 20580

Commissioner Orson Swindle
Federal Trade Commission
Room 540
600 Pennsylvania Ave, NW
Washington, DC 20580

Commissioner Thomas B. Leary
Federal Trade Commission
Room 528
600 Pennsylvania Ave, NW
Washington, DC 20580

Commissioner Pamela Jones Harbour
Federal Trade Commission
Room 326
600 Pennsylvania Ave, NW
Washington, DC 20580

Commissioner Jon D. Leibowitz
Federal Trade Commission
Room 340
600 Pennsylvania Ave, NW
Washington, DC 20580

Director Arden Bement, Jr.
National Institute of Science and Technology
100 Bureau Drive
Mail Stop 3460
Gaithersburg, MD 20899

Dear Chairperson Majoras:

The SPF Community is a recently formed group, established
to represent the interests of this community and to
carry forward with the work of email authentication as
represented by the Sender Policy Framework. This community
is comprised of many of the people who have been actively
involved in developing this framework.

We applaud the effort by the FTC and NIST to work with the
private sector in implementing one or more system wide
domain level authentication schemes to help secure email
and aid in thwarting the scourge of email forgery.

The potential real world effects of email authentication on
the online micro business community are significant. Great
strides have been made over the last 10 years in developing
a highly efficient email infrastructure. Unfortunately, the
plague of unsolicited bulk email, along with the spread of
viruses and trojans has reached crisis proportions,
threatening the continued viability of email as a
communications medium.

It is imperative that the online community as a whole
tackle these problems. We must work together in bringing
those who abuse email under control. But prudence is
important in carrying out these efforts. 

* Technological means can only go so far in controlling
online social problems.

* The implementation costs of any authentication proposal
must not outweigh the real or perceived benefits. 

* The email infrastructure is complex, having grown
organically over the years. Care must be taken to ensure
any proposal easily fits within this structure without
breaking any of its parts.

* The vast majority of those who work and play online are
not truly computer literate. Therefore any authentication
methods must be robust and easy to implement.

Presently there are various proposed methods of email
authentication. 

IP/Domain based authentication

IP/Domain based authentication relying on the Sender Policy
Framework (SPF) or Sender ID Framework (SIDF) allows for
last hop validation. 

The benefit of this approach is that it combines mail
channel authentication using the fully qualified domain
name (FQDN) found in SMTP MAIL FROM and message
authentication using the Purported Responsible Address
(PRA) Algorithm. 

However, initial studies suggest these approaches may
impose significant overhead requirements. 

Compatible Low-overhead Email Authentication and
Responsibility (CLEAR) focuses in part on mail channel
authentication and domain accreditation using the IP
address, based on the FQDN found in the EHELO/HELO command.
This allows for end to end validation and accreditation,
while apparently imposing less overhead requirements.

Cryptographic Methods

At the same time, light weight cryptographic approaches
seem to afford a better approach to allow for an effective
mechanism to properly verify whether to send a non-delivery
report or delivery status notification (Bounce Address Tag
Validation [BATV]). 

Also, it is perceived validating RFC 2822 from (in
particular Identified Internet Mail - CISCO and DomainKeys
- Yahoo!), so allowing for message authentication may be
best carried out using cryptographic methods.

The Crisis

The online community's frustration with the spam epidemic
and especially the dramatic rise in phishing has created a
crisis atmosphere.

Proceeding Forward

Given this crisis, there is a strong desire in certain
circles to simply proceed with one IP/Domain based approach
to provide an immediate response to the dramatic rise in
phishing attacks. 

However, all of the IP/Domain based proposals are
experimental in nature. In shutting down MARID, the IESG
stated in part:

"The working group chairs and Area Advisor intend to ask
that the editors of existing working group drafts put
forward their documents as non-working group submissions
for Experimental RFC status. Given the importance of the
world-wide email and DNS systems, it is critical that
IETF-sponsored experimental proposals likely to see broad
deployment contain no mechanisms that would have
deleterious effects on the overall system. The Area
Directors intend, therefore, to request that the
experimental proposals be reviewed by a focused technology
directorate."

Accordingly, this process should be carried out as quickly
as possible.

At the same time we can proceed with testing of the various
approaches on a wider scale to verify or disprove existing
views, develop the required code in some cases, work out
any bugs and, where possible, simplify the implementation
process.

Once testing is completed a better analysis can be
conducted of the competing methods. Based on initial
analysis and the complexity of the email infrastructure, it
is quite likely that a layered approach is required. This
analysis can then guide the community in selecting the
proper methods and making the needed investment in Internet
wide deployment.

Another concern is that some of these schemes are subject
to intellectual property right claims. To ensure wide
spread deployment and an equal playing field, we would urge
that any licenses be royalty free and fully compliant with
the Open Standards Alliance model.

In addition, work is required on the accreditation
(reputation) front. However, the ISPs need to be prepared
to work with the various proponents.

Unfortunately the lack of an industry standard for
establishing consent to receive solicited bulk email
continues to cause problems. In essence, with the largest
direct marketing association in the United States
advocating an opt-out approach, mail box providers are
obliged to respond by letting their customers decide what
is or is not spam.

This means a sender's reputation is evaluated against a
subjective standard, making it difficult to proceed with
reliable approaches for accreditation (reputation). 

The FTC and NIST can play a fundamental role in assisting
industry to sort through acceptable technical guidelines
for establishing consent. This will aid in ensuring that
the process of establishing and maintaining a reputation is
as objective as possible from the sender's and receiver's
perspective.

We recommend the following:

* The editors of the various IP/Domain based working group
drafts submitted during MARID follow the IESG directive and
put forward their documents as non-working group drafts.

* The IETF Area directors proceed to form the focused
technical directorate.

* The technical directorate carry out its work as quickly
as possible with the full co-operation of the respective
editors.

* Once this is done, the IESG proceed forward with its
process of determining which proposals should receive RFC
Experimental Status.

* While this work is ongoing, the major ISPs can gear up to
conduct large scale tests over the upcoming months. At the
same time smaller networks, along with individuals should
be given the opportunity to participate. 

* The results of these tests be made available to the
participants. The FTC and NIST can then convene a workshop
in the new year with participation from all stakeholders to
review these tests and consider the next stage in the
process.

* At the same time, significant education is required to
aid the community at large in moving forward. For example,
while some may consider the process of publishing an
appropriate email policy record using the SPF syntax is
quite simple, given the various ways of sending email, it
can be complex even for those with relatively straight
forward business environments. The FTC and NIST can assist
in this process by working with the proponents in producing
the needed guides and easy to use tools to aid the
community in implementing the various protocols.

* The FTC work with the United States Patent & Trade Mark
office and those claiming intellectual property rights to
ensure all claims are properly brought forward and any
licenses for use of core technologies are
non-discriminatory, royalty free and compliant with the
Open Standards Alliance model to allow for wide spread
deployment. This is especially important, given that open
source software predominates throughout the email
infrastructure.

* The FTC and NIST monitor developments on the
accreditation front. ISPs and others need to be prepared to
work with a number of providers. The FTC can encourage this
process so that accreditation does not form a market
barrier, while at the same time raising levels of online
compliance.

* In the interim, the NIST can facilitate the ISPs in
implementing the required technologies to allow for
validation of financial web sites as suggested in the 2nd
OECD Workshop on Spam Report to help deal with phishing
attacks, so protecting all consumers while the community
works on testing, analyzing and implementing email
authentication.

* To date industry has been unable to settle on standards
for consent, given the wide range of views. The FTC and
NIST can facilitate the process of establishing standards
by working with senders and receivers in establishing
technical requirements.

We appreciate this is a rather long list of
recommendations. Email now forms an important part of our
way of life and a fundamental element in operating an
online business. We trust that you will give consideration
to our comments and suggestions.

We thank you for your attention to these matters.

Yours truly,

The SPF Community



By: Acting Chair

/jbg

Please understand this position is deliberately neutral as
to the competing merits of the various proposals. I am
suggesting this stance, so we can stop the process of
"politicking" and people can get back to the job of
'serious' doing based on fair exchange of ideas, along with
thoughtful consideration of concepts and approaches as we
move forward with the technical review, testing,
implementation and evaluation.

Trusting this is helpful.

John

P.S. I apologize for the length of this message.

John Glube 
Toronto, Canada

http://www.trusted-email-sender.com 

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