RFC9448: TNAuthList Profile of Automated Certificate Management Environment (ACME) Authority Token

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Internet Engineering Task Force (IETF)                          C. Wendt
Request for Comments: 9448                                    D. Hancock
Category: Standards Track                                     Somos Inc.
ISSN: 2070-1721                                                M. Barnes
                                                             J. Peterson
                                                            Neustar Inc.
                                                          September 2023

   TNAuthList Profile of Automated Certificate Management Environment
                         (ACME) Authority Token


   This document defines a profile of the Automated Certificate
   Management Environment (ACME) Authority Token for the automated and
   authorized creation of certificates for Voice over IP (VoIP)
   telephone providers to support Secure Telephone Identity (STI) using
   the TNAuthList defined by STI certificates.

Status of This Memo

   This is an Internet Standards Track document.

   This document is a product of the Internet Engineering Task Force
   (IETF).  It represents the consensus of the IETF community.  It has
   received public review and has been approved for publication by the
   Internet Engineering Steering Group (IESG).  Further information on
   Internet Standards is available in Section 2 of RFC 7841.

   Information about the current status of this document, any errata,
   and how to provide feedback on it may be obtained at

Copyright Notice

   Copyright (c) 2023 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents
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   publication of this document.  Please review these documents
   carefully, as they describe your rights and restrictions with respect
   to this document.  Code Components extracted from this document must
   include Revised BSD License text as described in Section 4.e of the
   Trust Legal Provisions and are provided without warranty as described
   in the Revised BSD License.

Table of Contents

   1.  Introduction
   2.  Requirements Language
   3.  ACME New-Order Identifiers for TNAuthList
   4.  TNAuthList Identifier Authorization
   5.  TNAuthList Authority Token
     5.1.  "iss" Claim
     5.2.  "exp" Claim
     5.3.  "jti" Claim
     5.4.  "atc" Claim
     5.5.  Acquiring the Token from the Token Authority
     5.6.  Token Authority Responsibilities
     5.7.  Scope of the TNAuthList
   6.  Validating the TNAuthList Authority Token
   7.  Using ACME-Issued Certificates with JSON Web Signature
   8.  Usage Considerations
     8.1.  Large Number of Noncontiguous TNAuthList Values
   9.  IANA Considerations
   10. Security Considerations
   11. References
     11.1.  Normative References
     11.2.  Informative References
   Authors' Addresses

1.  Introduction

   [RFC8555] describes a mechanism for automating certificate management
   on the Internet.  It enables administrative entities to prove
   effective control over resources like domain names, and it automates
   the process of generating and issuing certificates.  [RFC9447]
   extends ACME to provide a general method of extending the authority
   and authorization of entities to control a resource via a third party
   Token Authority beyond the certification authority (CA).

   This document is a profile document using the Authority Token
   mechanism defined in [RFC9447].  It is a profile that specifically
   addresses the Secure Telephone Identity Revisited (STIR) problem
   statement described in [RFC7340], which identifies the need for
   Internet credentials that can attest authority for the originator of
   VoIP calls in order to detect impersonation, which is currently an
   enabler for common attacks associated with illegal robocalling,
   voicemail hacking, and swatting.  These credentials are used to sign
   Personal Assertion Tokens (PASSporTs) [RFC8225], which can be carried
   in using protocols such as SIP [RFC8224].  Currently, the only
   defined credentials for this purpose are the certificates specified
   in [RFC8226] using the TNAuthList.  This document defines the use of
   the TNAuthList Authority Token in the ACME challenge to prove the
   authoritative use of the contents of the TNAuthList, including a
   Service Provider Code (SPC), a telephone number, or a set of
   telephone numbers or telephone number blocks.

   This document also describes the ability for a telephone authority to
   authorize the creation of CA types of certificates for delegation, as
   defined in [RFC9060].

2.  Requirements Language

   The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT",
   "OPTIONAL" in this document are to be interpreted as described in
   BCP 14 [RFC2119] [RFC8174] when, and only when, they appear in all
   capitals, as shown here.

3.  ACME New-Order Identifiers for TNAuthList

   Section 7 of [RFC8555] defines the procedure that an ACME client uses
   to order a new certificate from a CA.  The new-order request contains
   an identifier field that specifies the identifier objects the order
   corresponds to.  This document defines a new type of identifier
   object called TNAuthList.  A TNAuthList identifier contains the
   identity information to be populated in the TNAuthList of the new
   certificate.  For the TNAuthList identifier, the new-order request
   includes a type set to the string "TNAuthList".  The value of the
   TNAuthList identifier MUST be set to the details of the TNAuthList

   The string that represents the TNAuthList MUST be constructed using
   base64url encoding, as described in Section 5 of [RFC4648] and as
   defined in Section 2 of JSON Web Signature [RFC7515].  The base64url
   encoding MUST NOT include any padding characters, and the TNAuthList
   ASN.1 object MUST be encoded using DER encoding rules.

   An example of an ACME order object "identifiers" field containing a
   TNAuthList certificate is as follows:

    "identifiers": [{"type":"TNAuthList","value":"F83n2a...avn27DN3"}]

   where the "value" object string represents the arbitrary length of
   the base64url-encoded string.

   A full new-order request would look as follows:

   POST /acme/new-order HTTP/1.1
   Host: example.com
   Content-Type: application/jose+json

     "protected": base64url({
       "alg": "ES256",
       "kid": "https://example.com/acme/acct/evOfKhNU60wg",
       "nonce": "5XJ1L3lEkMG7tR6pA00clA",
       "url": "https://example.com/acme/new-order"
     "payload": base64url({
       "identifiers": [{"type":"TNAuthList","value":"F83n...n27DN3"}],
       "notBefore": "2021-01-01T00:00:00Z",
       "notAfter": "2021-01-08T00:00:00Z"
     "signature": "H6ZXtGjTZyUnPeKn...wEA4TklBdh3e454g"

   On receiving a valid new-order request, the ACME server creates an
   authorization object ([RFC8555], Section 7.1.4), containing the
   challenge that the ACME client must satisfy to demonstrate authority
   for the identifiers specified by the new order (in this case, the
   TNAuthList identifier).  The CA adds the authorization object URL to
   the "authorizations" field of the order object and returns the order
   object to the ACME client in the body of a 201 (Created) response.

   HTTP/1.1 201 Created
   Content-Type: application/json
   Replay-Nonce: MYAuvOpaoIiywTezizk5vw
   Location: https://example.com/acme/order/1234

     "status": "pending",
     "expires": "2022-01-08T00:00:00Z",

     "notBefore": "2022-01-01T00:00:00Z",
     "notAfter": "2022-01-08T00:00:00Z",

     "authorizations": [
     "finalize": "https://example.com/acme/order/1234/finalize"

4.  TNAuthList Identifier Authorization

   On receiving the new-order response, the ACME client queries the
   referenced authorization object to obtain the challenges for the
   identifier contained in the new-order request, as shown in the
   following example request and response.

   POST /acme/authz/1234 HTTP/1.1
       Host: example.com
       Content-Type: application/jose+json

         "protected": base64url({
           "alg": "ES256",
           "kid": " https://example.com/acme/acct/evOfKhNU60wg",
           "nonce": "uQpSjlRb4vQVCjVYAyyUWg",
           "url": "https://example.com/acme/authz/1234"
         "payload": "",
         "signature": "nuSDISbWG8mMgE7H...QyVUL68yzf3Zawps"

   HTTP/1.1 200 OK
   Content-Type: application/json
   Link: <https://example.com/acme/some-directory>;rel="index"

     "status": "pending",
     "expires": "2022-01-08T00:00:00Z",

     "identifier": {

     "challenges": [
         "type": "tkauth-01",
         "tkauth-type": "atc",
         "token-authority": "https://authority.example.org",
         "url": "https://example.com/acme/chall/prV_B7yEyA4",
         "token": "IlirfxKKXAsHtmzK29Pj8A"

   When processing a certificate order containing an identifier of type
   "TNAuthList", a CA uses the Authority Token challenge type of
   "tkauth-01" with a "tkauth-type" of "atc" in [RFC9447] to verify that
   the requesting ACME client has authenticated and authorized control
   over the requested resources represented by the "TNAuthList" value.

   The challenge "token-authority" parameter is only used in cases where
   the VoIP telephone network requires the CA to identify the Token
   Authority.  This is currently not the case for the Signature-based
   Handling of Asserted information using toKENs (SHAKEN) [ATIS-1000080]
   certificate framework governance but may be used by other frameworks.
   If a "token-authority" parameter is present, then the ACME client MAY
   use the "token-authority" value to identify the URL representing the
   Token Authority that will provide the TNAuthList Authority Token
   response to the challenge.  If the "token-authority" parameter is not
   present, then the ACME client MUST identify the Token Authority based
   on locally configured information or local policies.

   The ACME client responds to the challenge by posting the TNAuthList
   Authority Token to the challenge URL identified in the returned ACME
   authorization object, an example of which follows:

   POST /acme/chall/prV_B7yEyA4 HTTP/1.1
   Host: boulder.example.com
   Content-Type: application/jose+json

     "protected": base64url({
     "alg": "ES256",
     "kid": "https://example.com/acme/acct/evOfKhNU60wg",
     "nonce": "Q_s3MWoqT05TrdkM2MTDcw",
     "url": "https://boulder.example.com/acme/authz/asdf/0"
     "payload": base64url({
     "tkauth": "DGyRejmCefe7v4N...vb29HhjjLPSggwiE"
     "signature": "9cbg5JO1Gf5YLjjz...SpkUfcdPai9uVYYQ"

   The "tkauth" field is defined as a new field in the challenge object
   specific to the tkauth-01 challenge type that should contain the
   TNAuthList Authority Token defined in the next section.

5.  TNAuthList Authority Token

   The TNAuthList Authority Token is a profile instance of the ACME
   Authority Token defined in [RFC9447].

   The TNAuthList Authority Token protected header MUST comply with
   "Request Authentication" (Section 6.2 of [RFC8555]).

   The TNAuthList Authority Token Payload MUST include the mandatory
   claims "exp", "jti", and "atc" and MAY include the optional claims
   defined for the Authority Token detailed in the next subsections.

5.1.  "iss" Claim

   The "iss" claim is an optional claim defined in [RFC7519],
   Section 4.1.1.  It can be used as a URL identifying the Token
   Authority that issued the TNAuthList Authority Token beyond the "x5u"
   or other header claims that identify the location of the certificate
   or certificate chain of the Token Authority used to validate the
   TNAuthList Authority Token.

5.2.  "exp" Claim

   The "exp" claim, defined in [RFC7519], Section 4.1.4, MUST be
   included and contains the DateTime value of the ending date and time
   that the TNAuthList Authority Token expires.

5.3.  "jti" Claim

   The "jti" claim, defined in [RFC7519], Section 4.1.7, MUST be
   included and contains a unique identifier for this TNAuthList
   Authority Token transaction.

5.4.  "atc" Claim

   The "atc" claim MUST be included and is defined in [RFC9447].  It
   contains a JSON object with the following elements:

   *  a "tktype" key with a string value equal to "TNAuthList" to
      represent a TNAuthList profile of the Authority Token [RFC9447]
      defined by this document. "tktype" is a required key and MUST be

   *  a "tkvalue" key with a string value equal to the base64url
      encoding of the TNAuthList certificate extension ASN.1 object
      using DER encoding rules. "tkvalue" is a required key and MUST be

   *  a "ca" key with a boolean value set to either true when the
      requested certificate is allowed to be a CA cert for delegation
      uses or false when the requested certificate is not intended to be
      a CA cert, only an end-entity certificate. "ca" is an optional
      key; if not included, the "ca" value is considered false by

   *  a "fingerprint" key constructed as defined in [RFC8555],
      Section 8.1, corresponding to the computation of the "Thumbprint"
      step using the ACME account key credentials. "fingerprint" is a
      required key and MUST be included.

   An example of the TNAuthList Authority Token is as follows:

     "protected": base64url({
     "payload": base64url({
         "fingerprint":"SHA256 56:3E:CF:AE:83:CA:4D:15:B0:29:FF:1B:71:
     "signature": "9cbg5JO1Gf5YLjjz...SpkUfcdPai9uVYYQ"

5.5.  Acquiring the Token from the Token Authority

   Following [RFC9447], Section 5, the Authority Token should be
   acquired using a RESTful HTTP POST transaction as follows:

     POST /at/account/:id/token HTTP/1.1
     Host: authority.example.org
     Content-Type: application/json

   The request will pass the account identifier as a string in the
   request parameter "id".  This string will be managed as an identifier
   specific to the Token Authority's relationship with a Communications
   Service Provider (CSP).  There is assumed to also be a corresponding
   authentication procedure that can be verified for the success of this
   transaction, for example, an HTTP authorization header containing
   valid authorization credentials, as defined in [RFC9110],
   Section 11.6.2.

   The body of the POST request MUST contain a JSON object with key
   value pairs corresponding to values that are requested as the content
   of the claims in the issued token.  As an example, the body SHOULD
   contain a JSON object as follows:

      "fingerprint":"SHA256 56:3E:CF:AE:83:CA:4D:15:B0:29:FF:1B:71:D3

   If successful, the response to the POST request returns a 200 (OK)
   with a JSON body that contains, at a minimum, the TNAuthList
   Authority Token as a JSON object with a key of "token" and the
   base64url-encoded string representing the atc token.  JSON is easily
   extensible, so users of this specification may want to pass other
   pieces of information relevant to a specific application.

   An example of a successful response would be as follows:

   HTTP/1.1 200 OK
   Content-Type: application/json

   {"token": "DGyRejmCefe7v4N...vb29HhjjLPSggwiE"}

   If the request is not successful, the response should indicate the
   error condition.  Specifically, for the case that the authorization
   credentials are invalid or if the account identifier provided does
   not exist, the response code MUST be 403 (Forbidden).  Other 4xx and
   5xx responses MUST follow standard HTTP error condition conventions

5.6.  Token Authority Responsibilities

   When creating the TNAuthList Authority Token, the Token Authority
   MUST validate that the information contained in the ASN.1 TNAuthList
   accurately represents the service provider code (SPC) or telephone
   number (TN) resources the requesting party is authorized to represent
   based on their pre-established, verified, and secure relationship
   between the Token Authority and the requesting party.  Note that the
   fingerprint in the token request is not meant to be verified by the
   Token Authority but rather is meant to be signed as part of the token
   so that the party that requests the token can, as part of the
   challenge response, allow the ACME server to validate that the token
   requested and used came from the same party that controls the ACME

5.7.  Scope of the TNAuthList

   Because this specification specifically involves the TNAuthList
   defined in [RFC8226], which involves SPC, telephone number ranges,
   and individual telephone numbers, the client may also request an
   Authority Token with some subset of its own authority as the
   TNAuthList provided in the "tkvalue" element in the "atc" JSON
   object.  Generally, the scope of authority representing a CSP is
   represented by a particular SPC (e.g., in North America, an operating
   company number (OCN) or service provider identifier (SPID)).  Based
   on number allocations, that provider is also generally associated
   with a particular set of different telephone number ranges and/or
   telephone numbers.  The TNAuthList can be constructed to define a
   limited scope of the TelephoneNumberRanges or TelephoneNumbers
   ([RFC8226], Section 9) either associated with an SPC or with the
   scope of telephone number ranges or telephone numbers the client has
   authority over.

   As recommended in the Security Considerations section in [RFC9447],
   an Authority Token can either have a scope that attests all of the
   resources that a client is eligible to receive certificates for or
   potentially a more limited scope that is intended to capture only
   those resources for which a client will receive a certificate from a
   particular certification authority.  Any certification authority that
   sees an Authority Token can learn information about the resources a
   client can claim.  In cases where this incurs a privacy risk,
   Authority Token scopes should be limited to only the resources that
   will be attested by the requested ACME certificate.

6.  Validating the TNAuthList Authority Token

   Upon receiving a response to the challenge, the ACME server MUST
   perform the following steps to determine the validity of the

   1.  Verify that the value of the "atc" claim is a well-formed JSON
       object containing the mandatory key values.

   2.  If there is an "x5u" parameter, verify the "x5u" parameter is an
       HTTPS URL with a reference to a certificate representing the
       trusted issuer of Authority Tokens for the ecosystem.

   3.  If there is an "x5c" parameter, verify the certificate array
       contains a certificate representing the trusted issuer of
       Authority Tokens for the ecosystem.

   4.  Verify the TNAuthList Authority Token signature using the public
       key of the certificate referenced by the token's "x5u" or "x5c"

   5.  Verify that "atc" claim contains a "tktype" identifier with the
       value "TNAuthList".

   6.  Verify that the "atc" claim "tkvalue" identifier contains the
       equivalent base64url-encoded TNAuthList certificate extension
       string value as the identifier specified in the original

   7.  Verify that the remaining claims are valid (e.g., verify that
       token has not expired).

   8.  Verify that the "atc" claim "fingerprint" is valid and matches
       the account key of the client making the request.

   9.  Verify that the "atc" claim "ca" identifier boolean corresponds
       to the CA boolean in the Basic Constraints extension in the
       Certificate Signing Request (CSR) for either CA certificate or
       end-entity certificate.

   If all steps in the token validation process pass, then the ACME
   server MUST set the challenge object "status" to "valid".  If any
   step of the validation process fails, the "status" in the challenge
   object MUST be set to "invalid".

7.  Using ACME-Issued Certificates with JSON Web Signature

   JSON Web Signature (JWS) [RFC7515] objects can include an "x5u"
   header parameter to refer to a certificate that is used to validate
   the JWS signature.  For example, the STIR PASSporT framework
   [RFC8225] uses "x5u" to indicate the STIR certificate used to
   validate the PASSporT JWS object.  The URLs used in "x5u" are
   expected to provide the required certificate in response to a GET
   request, not a POST-as-GET, as required for the "certificate" URL in
   the ACME order object.  Thus, the current mechanism generally
   requires the ACME client to download the certificate and host it on a
   public URL to make it accessible to relying parties.  This section
   defines an optional mechanism for the certification authority (CA) to
   host the certificate directly and provide a URL that the ACME client
   owner can directly reference in the "x5u" of their signed PASSporTs.

   As described in Section 7.4 of [RFC8555], when the certificate is
   ready for making a "finalize" request, the server will return a 200
   (OK) with the updated order object.  In this response, an ACME server
   can add a newly defined field called "x5u" that can pass this URL to
   the ACME client for usage in generated PASSporTs as a publicly
   available URL for PASSporT validation.

   x5u (optional, string):  a URL that can be used to reference the
      certificate in the "x5u" parameter of a JWS object [RFC7515]

   The publishing of the certificates at the new "x5u" URL should follow
   the GET request requirement as mentioned above and should be
   consistent with the timely publication according to the durations of
   the certificate life cycle.

   The following is an example of the use of "x5u" in the response when
   the certificate status is "valid".

   HTTP/1.1 200 OK
   Content-Type: application/json
   Replay-Nonce: CGf81JWBsq8QyIgPCi9Q9X
   Link: <https://example.com/acme/directory>;rel="index"
   Location: https://example.com/acme/order/TOlocE8rfgo

     "status": "valid",
     "expires": "2016-01-20T14:09:07.99Z",

     "notBefore": "2016-01-01T00:00:00Z",
     "notAfter": "2016-01-08T00:00:00Z",

     "identifiers": [

     "authorizations": ["https://sti-ca.com/acme/authz/1234"],

     "finalize": "https://example.com/acme/order/TOlocE8rfgo/finalize",

     "certificate": "https://example.com/acme/cert/mAt3xBGaobw",

     "x5u": "https://example.com/cert-repo/giJI53km23.pem"

8.  Usage Considerations

8.1.  Large Number of Noncontiguous TNAuthList Values

   There are many scenarios and reasons to have various combinations of
   SPCs, TNs, and TN ranges.  [RFC8226] has provided a somewhat
   unbounded set of combinations.  It's possible that a complex
   noncontiguous set of telephone numbers are being managed by a CSP.
   Best practice may be simply to split a set of noncontiguous numbers
   under management into multiple STI certificates to represent the
   various contiguous parts of the greater noncontiguous set of TNs,
   particularly if the length of the set of values in an identifier
   object grows to be too large.

9.  IANA Considerations

   Per this document, IANA has added a new identifier object type to the
   "ACME Identifier Types" registry defined in Section 9.7.7 of

                        | Label      | Reference |
                        | TNAuthList | RFC 9448  |

                                 Table 1

10.  Security Considerations

   The token represented by this document has the credentials to
   represent the scope of a telephone number, a block of telephone
   numbers, or an entire set of telephone numbers represented by an SPC.
   The creation, transport, and any storage of this token MUST follow
   the strictest of security best practices beyond the recommendations
   of the use of encrypted transport protocols in this document to
   protect it from getting in the hands of bad actors with illegitimate
   intent to impersonate telephone numbers.

   This document inherits the security properties of [RFC9447].
   Implementations should follow the best practices identified in

   This document only specifies SHA256 for the fingerprint hash.
   However, the syntax of the fingerprint object would permit other
   algorithms if, due to concerns about algorithmic agility, a more
   robust algorithm were required at a future time.  Future
   specifications can define new algorithms for the fingerprint object
   as needed.

11.  References

11.1.  Normative References

   [RFC2119]  Bradner, S., "Key words for use in RFCs to Indicate
              Requirement Levels", BCP 14, RFC 2119,
              DOI 10.17487/RFC2119, March 1997,

   [RFC4648]  Josefsson, S., "The Base16, Base32, and Base64 Data
              Encodings", RFC 4648, DOI 10.17487/RFC4648, October 2006,

   [RFC7515]  Jones, M., Bradley, J., and N. Sakimura, "JSON Web
              Signature (JWS)", RFC 7515, DOI 10.17487/RFC7515, May
              2015, <https://www.rfc-editor.org/info/rfc7515>.

   [RFC7519]  Jones, M., Bradley, J., and N. Sakimura, "JSON Web Token
              (JWT)", RFC 7519, DOI 10.17487/RFC7519, May 2015,

   [RFC8174]  Leiba, B., "Ambiguity of Uppercase vs Lowercase in RFC
              2119 Key Words", BCP 14, RFC 8174, DOI 10.17487/RFC8174,
              May 2017, <https://www.rfc-editor.org/info/rfc8174>.

   [RFC8226]  Peterson, J. and S. Turner, "Secure Telephone Identity
              Credentials: Certificates", RFC 8226,
              DOI 10.17487/RFC8226, February 2018,

   [RFC8555]  Barnes, R., Hoffman-Andrews, J., McCarney, D., and J.
              Kasten, "Automatic Certificate Management Environment
              (ACME)", RFC 8555, DOI 10.17487/RFC8555, March 2019,

   [RFC8725]  Sheffer, Y., Hardt, D., and M. Jones, "JSON Web Token Best
              Current Practices", BCP 225, RFC 8725,
              DOI 10.17487/RFC8725, February 2020,

   [RFC9060]  Peterson, J., "Secure Telephone Identity Revisited (STIR)
              Certificate Delegation", RFC 9060, DOI 10.17487/RFC9060,
              September 2021, <https://www.rfc-editor.org/info/rfc9060>.

   [RFC9110]  Fielding, R., Ed., Nottingham, M., Ed., and J. Reschke,
              Ed., "HTTP Semantics", STD 97, RFC 9110,
              DOI 10.17487/RFC9110, June 2022,

   [RFC9447]  Peterson, J., Barnes, M., Hancock, D., and C. Wendt,
              "Automated Certificate Management Environment (ACME)
              Challenges Using an Authority Token", RFC 9447,
              DOI 10.17487/RFC9447, September 2023,

11.2.  Informative References

              ATIS, "Signature-based Handling of Asserted information
              using toKENs (SHAKEN): Governance Model and Certificate
              Management", ATIS-1000080.v005, December 2022,

   [RFC7340]  Peterson, J., Schulzrinne, H., and H. Tschofenig, "Secure
              Telephone Identity Problem Statement and Requirements",
              RFC 7340, DOI 10.17487/RFC7340, September 2014,

   [RFC8224]  Peterson, J., Jennings, C., Rescorla, E., and C. Wendt,
              "Authenticated Identity Management in the Session
              Initiation Protocol (SIP)", RFC 8224,
              DOI 10.17487/RFC8224, February 2018,

   [RFC8225]  Wendt, C. and J. Peterson, "PASSporT: Personal Assertion
              Token", RFC 8225, DOI 10.17487/RFC8225, February 2018,


   We would like to thank Richard Barnes and Russ Housley for valuable
   contributions to this document.

Authors' Addresses

   Chris Wendt
   Somos Inc.
   United States of America
   Email: chris-ietf@chriswendt.net

   David Hancock
   Somos Inc.
   United States of America
   Email: davidhancock.ietf@gmail.com

   Mary Barnes
   Neustar Inc.
   United States of America
   Email: mary.ietf.barnes@gmail.com

   Jon Peterson
   Neustar Inc.
   Suite 570
   1800 Sutter St
   Concord, CA 94520
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