Paul, These statements are not based on "feelings". They are based on experience of doing third party testing such as TPEP (TCSEC), TTAP (TCSEC and CC), CC testing and FIPS since 1987 and being involved in the FIPS program since its pre-formative days. If there are specific concerns, I would be happy to look into those. My general observation is that vendors do not assign their engineers to these efforts and there is a dearth of qualified testers, resulting in blind leading the blind. If you get a good tester, he/she will force the vendor to provide a good engineering answer and many of the general issues you are mentioning will get tackled right. I would recommend that VPNC members/vendors have good engineers making sound arguments. Most of the times, that works. -----Original Message----- From: Paul Hoffman [mailto:paul.hoffman at vpnc.org] Sent: Tuesday, February 19, 2008 1:04 PM To: Santosh Chokhani; Stephen Kent Cc: saag at mit.edu; Randall Atkinson Subject: RE: [saag] Algorithms/modes requested by users/customers At 11:49 AM -0500 2/19/08, Santosh Chokhani wrote: >On the issue of restart, that is misunderstanding on Paul's part. There >is no restart. Ahem. I am reporting what the members of VPNC report to me. They are the vendors in the testing, not me. I have heard this from multiple vendors. If I was not clear that I was reporting what others said, I apologize. >Generally, problem is fixed and you pick up that point. Not to be too picky, but how can you say "generally" without seeing every test that was stopped? Maybe you have not had this problem, but others say they have. >Subjective tests seems to be misunderstanding on Paul's part. Having >been in the Orange Book, CC and FIPS process, I as validator, tester, >and certifier as well as vendor generally rue about rigidness of the >standard and lack of subjective judgment on the part of the tester or >lack of subjective latitude to vendors. If you, as a tester, feel that there are no subjective parts of the test process, that's fine. Some/many people who are being tested disagree with you. >FIPS 140 has specific guidelines on how to deal with minor incremental >changes that helps reduce cost and calendar time. Great! It does not seem to have gotten through to the vendors themselves as "inexpensive enough" or "fast enough". As a tester, you may have a different view. >The standard is NOT a protocol standard. It does verify the algorithm >implementations and thus, FIPS validated algorithms can interoperate. Quite true. >In terms of low end devices, 20-30K for level 1 testing amortized over >devices does not seem too onerous. ...to you. Others disagree, both on the financial cost, and particularly on the cost of elapsed time before customers can use the latest release from a vendor. >I do not understand what Paul refers to as silly modes. The module >being FIPS validated must use FIPS validated or recognized algorithms >for a given crypto service. That seems like a good thing to me. That is a good thing; it is also not what I was talking about. There is disagreement about what needs to be in a "FIPS mode", and whether the shipped product needs to allow "FIPS mode" to be enabled, and if so, how. Again: I am reporting what I hear from many VPNC members over many years. You as a single vendor and/or tester might feel differently; your feeling does not invalidate the views of others. --Paul Hoffman, Director --VPN Consortium
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