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Date: Fri, 15 Dec 2000 21:10:58 -0600
To: crypto-gram@chaparraltree.com
From: Bruce Schneier <schneier@counterpane.com>
Subject: CRYPTO-GRAM, December 15, 2000

                  CRYPTO-GRAM

               December 15, 2000

               by Bruce Schneier
                Founder and CTO
       Counterpane Internet Security, Inc.
            schneier@counterpane.com
          <http://www.counterpane.com>


A free monthly newsletter providing summaries, analyses, insights, and 
commentaries on computer security and cryptography.

Back issues are available at <http://www.counterpane.com>.  To subscribe or 
unsubscribe, see below.


Copyright (c) 2000 by Counterpane Internet Security, Inc.


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In this issue:
      Voting and Technology
      Crypto-Gram Reprints
      News
      Counterpane Internet Security News
      Crypto-Gram News
      IBM's New Crypto Mode of Operation
      Solution in Search of a Problem: Digital Safe-Deposit Boxes
      New Bank Privacy Regulations
      Comments from Readers


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             Voting and Technology



In the wake of last November's election, pundits have called for more 
accurate voting and vote counting.  To most people, this obviously means 
more technology.  But before jumping to conclusions, let's look at the 
security and reliability issues surrounding voting technology.

The goal of any voting system is to establish the intent of the voter, and 
transfer that intent to the vote counter.   Amongst a circle of friends, a 
show of hands can easily decide which movie to attend.  The vote is open 
and everyone can monitor it.  But what if Alice wants _Charlie's Angels_ 
and Bob wants _102 Dalmatians_?  Will Alice vote in front of his 
friends?  Will Bob?  What if the circle of friends is two hundred; how long 
will it take to count the votes?  Will the theater still be showing the 
movie?  Because the scale changes, our voting methods have to change.

Anonymity requires a secret ballot.  Scaling and speed requirements lead to 
mechanical and computerized voting systems.  The ideal voting technology 
would have these five attributes:  anonymity, scalability, speed, audit, 
and accuracy -- direct mapping from intent to counted vote.

Through the centuries, different technologies have done their best.  Stones 
and pot shards dropped in Greek vases led to paper ballots dropped in 
sealed boxes.  Mechanical voting booths and punch cards replaced paper 
ballots for faster counting.  New computerized voting machines promise even 
more efficiency, and Internet voting even more convenience.

But in the rush to improve the first four attributes, accuracy has been 
sacrificed.  The way I see it, all of these technologies involve 
translating the voter's intent in some way; some of them involve multiple 
translations.  And at each translation step, errors accumulate.

This is an important concept, and one worth restating.  Accuracy is not how 
well the ballots are counted by, for example, the optical scanner; it's how 
well the process translates voter intent into properly counted votes.

Most of Florida's voting irregularities are a direct result of these 
translation errors.  The Palm Beach system had several translation steps: 
voter to ballot to punch card to card reader to vote tabulator to 
centralized total.  Some voters were confused by the layout of the ballot, 
and mistakenly voted for someone else.  Others didn't punch their ballots 
so that the tabulating machines could read them.  Ballots were lost and not 
counted.  Machines broke down, and they counted ballots 
improperly.  Subtotals were lost and not counted in the final total.

Certainly Florida's antiquated voting technology is partially to blame, but 
newer technology wouldn't magically make the problems go away.  It could 
even make things worse, by adding more translation layers between the 
voters and the vote counters and preventing recounts.

That's my primary concern about computer voting: There is no paper ballot 
to fall back on.  Computerized voting machines, whether they have keyboard 
and screen or a touch screen ATM-like interface, could easily make things 
worse.  You have to trust the computer to record the votes properly, 
tabulate the votes properly, and keep accurate records.  You can't go back 
to the paper ballots and try to figure out what the voter wanted to 
do.  And computers are fallible; some of the computer voting machines in 
this election failed mysteriously and irrecoverably.

Online voting schemes have even more potential for failure and abuse.  We 
know we can't protect Internet computers from viruses and worms, and that 
all the operating systems are vulnerable to attack.  What recourse is there 
if the voting system is hacked, or simply gets overloaded and fails?  There 
would be no means of recovery, no way to do a recount.  Imagine if someone 
hacked the vote in Florida; redoing the election would be the only possible 
solution.  A secure Internet voting system is theoretically possible, but 
it would be the first secure networked application *ever created* in the 
history of computers.

There are other, less serious, problems with online voting.  First, the 
privacy of the voting booth cannot be imitated online.  Second, in any 
system where the voter is not present, the ballot must be delivered tagged 
in some unique way so that people know it comes from a registered voter who 
has not voted before.  Remote authentication is something we've not gotten 
right yet.  (And no, biometrics don't solve this problem.)  These problems 
also exist in absentee ballots and mail-in elections, and many states have 
decided that the increased voter participation is more than worth the 
risks.  But because online systems have a central point to attack, the 
risks are greater.

The ideal voting system would minimize the number of translation steps, and 
make those remaining as simple as possible.  My suggestion is an ATM-style 
computer voting machine, but one that also prints out a paper ballot.  The 
voter checks the paper ballot for accuracy, and then drops it into a sealed 
ballot box.  The paper ballots are the "official" votes and can be used for 
recounts, and the computer provides a quick initial tally.

Even this system is not as easy to design and implement as it sounds.  The 
computer would need to be treated like safety- and mission-critical 
systems: fault tolerant, redundant, carefully analyzed code.  Adding the 
printer adds problems; it's yet another part to fail.  And these machines 
will only be used once a year, making it even harder to get right.

But in theory, this could work.  It would rely on computer software, with 
all those associated risks, but the paper ballots would provide the ability 
to recount by hand if necessary.

Even with a system like this, we need to realize that the risk of errors 
and fraud cannot be brought down to zero.  Cambridge Professor Roger 
Needham once described automation as replacing what works with something 
that almost works, but is faster and cheaper.  We need to decide what's 
more important, and what tradeoffs we're willing to make.


This is *the* Web site on electronic voting.  Rebecca Mercuri wrote her PhD 
thesis on the topic, and it is well worth reading.
<http://www.notablesoftware.com/evote.html>

Good balanced essays:
<http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/2000/12/0 
4/BU91811.DTL>
<http://www.securityfocus.com/frames/?content=/templates/article.html%3Fid%3 
D114>
<http://www.sfgate.com/cgi-bin/article.cgi?file=/technology/archive/2000/11/ 
30/ballots.dtl>
<http://www.seas.upenn.edu:8080/~mercuri/Papers/RisksPGN.html>
<http://www.seas.upenn.edu:8080/~mercuri/Papers/voice.html>
<http://www.latimes.com/news/politics/decision2000/lat_vote001211.htm>
<http://www.usatoday.com/news/e98/e807.htm>
<http://www.pcworld.com/news/article.asp?aid=13719>
<http://www.nytimes.com/2000/11/17/politics/17MACH.html>

Pro-computer and Internet voting essays:
<http://www.wired.com/news/politics/0,1283,40141,00.html>
<http://www.zdnet.com/zdnn/stories/comment/0,5859,2652350,00.html>
<http://www.win2000mag.com/Articles/Index.cfm?ArticleID=16083>

Problems with New Mexico computerized vote-counting software:
<http://foxnews.com/election_night/111100/newmexico_bush.sml>


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             Crypto-Gram Reprints



The Fallacy of Cracking Contests:
<http://www.counterpane.com/crypto-gram-9812.html#contests>

How to Recognize Plaintext:
<http://www.counterpane.com/crypto-gram-9812.html#plaintext>

"Security is a process, not a product."
<http://www.counterpane.com/crypto-gram-9912.html#SecurityIsNotaProductItsaP 
rocess>

Echelon Technology:
<http://www.counterpane.com/crypto-gram-9912.html#ECHELONTechnology>

European Digital Cellular Algorithms:
<http://www.counterpane.com/crypto-gram-9912.html#EuropeanCellularEncryption 
Algorithms>


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                     News



One of the problems facing a network security administrator is that there 
are simply too many alerts to deal with:
<http://www.zdnet.com/enterprise/stories/security/0,12379,2651205,00.html>

Secret (and unauthorized) CIA chat room:
<http://www.zdnet.com/zdnn/stories/news/0,4586,2652732,00.html>
<http://www.washingtonpost.com/ac2/wp-dyn/A64444-2000Nov11?language=printer>
<http://www.cnn.com/2000/TECH/computing/11/12/cia.chat/index.html>
<http://www.nytimes.com/2000/12/01/technology/01WIRE-CIA.html>

The world's first cybercrime treaty is being hastily redrafted after 
Internet lobby groups assailed it as a threat to human rights that could 
have "a chilling effect on the free flow of information and ideas."
<http://www.wired.com/news/politics/0,1283,40134,00.html>
<http://slashdot.org/yro/00/11/13/1828213.shtml>

A Field Guide for Investigating Computer Crime.  Five parts, very interesting:
<http://www.securityfocus.com/frames/?focus=ih&content=/focus/ih/articles/cr 
imeguide1.html>

Interview with Vincent Rijmen (one of the authors of Rijndael) about AES:
<http://www.planetit.com/techcenters/docs/security/qa/PIT20001106S0015>

Microsoft's Ten Immutable Laws of Security.  A good list, actually.
<http://www.microsoft.com/technet/security/10imlaws.asp>

A new report claims that losses due to shoddy security cost $15B a 
year.  Investments in network security are less than half that.  Sounds 
like lots of people aren't doing the math.
<http://www.vnunet.com/News/1114075?&_ref=1732900718>
<http://www.thetimes.co.uk/article/0,,35878,00.html>

NESSIE is a European program for cryptographic algorithm standards (kind of 
like a European AES, only more general).  Here's a list of all the 
algorithms submitted to the competitions, with links to descriptive 
documents.  Great source for budding cryptanalysts.
<http://www.cryptonessie.org>
<https://www.cosic.esat.kuleuven.ac.be/nessie/workshop/>

More Carnivore information becomes public.  Among the information included 
in the documents was a sentence stating that the PC that is used to sift 
through e-mail "could reliably capture and archive all unfiltered traffic 
to the internal hard drive."  Since this directly contradicts the FBI's 
earlier public assertions, why should anyone trust them to speak truthfully 
about Carnivore in the future?
<http://news.cnet.com/news/0-1005-200-3731884.html>
<http://www.wired.com/news/politics/0,1283,40256,00.html>
Independent Carnivore review less than stellar:
<http://www.crypto.com/papers/carnivore_report_comments.html>
Carnivore: How it Works
<http://www.howthingswork.com/carnivore.htm>

Interesting biometrics reference site:
<http://homepage.ntlworld.com/avanti/>

The People for Internet Responsibility has a position paper on digital 
signatures.  Worth reading.
<http://www.pfir.org/statements/e-sigs>

The Global Internet Project has released a research paper entitled, 
"Security, Privacy and Reliability of the Next Generation Internet":
<http://www.gip.org/publications/papers/ngisecurityprimer.asp>

More on the stolen Enigma:  When it was returned, some rotors were still 
missing.  And there's been an arrest in the case.
<http://www.sunday-times.co.uk/news/pages/sti/2000/11/19/stinwenws02039.html>

The pros and cons of making attacks public:
<http://www.zdnet.com/enterprise/stories/main/0,10228,2652725,00.html>
<http://www.usatoday.com/life/cyber/tech/cti839.htm>
And the question of retaliation: should you strike back against hackers if 
the police can't do anything?
<http://computerworld.com/cwi/story/0,1199,NAV65-663_STO53869_NLTs,00.html>

Commentary on Microsoft's public response to their network being hacked.
<http://computerworld.com/cwi/story/0,1199,NAV65-663_STO53905_NLTs,00.html>

A review of cybercrime laws:
<http://www.upside.com/texis/mvm/upside_counsel?id=3a06fede1>

During WWII, MI5 tested Winston Churchill's wine for poison by injecting 
the stuff into rats.  This is a photo of a couple of very short typewritten 
pages detailing the report.
<http://www.churchill.nls.ac.uk/9.7new.html>

Internet users have filed a lawsuit against online advertiser MatchLogic 
Inc., alleging that their privacy was violated by the company's use of 
devices that track their Web browsing habits.
<http://www.denverpost.com/business/biz1122c.htm>

A Swiss bank, UBS AG, has just issued a warning bulletin to Outlook and 
Outlook Express users of its Internet banking service.  There is a virus 
out there that, when a customer attempts an Internet banking transaction, 
will present legitimate-looking HTML menus, prompt the user for his 
Internet banking passwords and security codes, and send the information to 
its own server.
<http://www.ubs.com/e/ebanking/classic/security.html>

Security and usability:
<http://www.useit.com/alertbox/20001126.html>

Top 50 Security Tools.  A good list, I think.
<http://www.insecure.org/tools.html>

Social engineering at its finest:  The Nov. 27 issue of _The New Yorker_ 
has a story written by someone who quit his job to write, but discovered he 
never got anything done at home.  So he strolled into the offices of an 
Internet startup and pretended to work there for 17 days.  He chose a desk, 
got on the phone list, drank free soda and got free massages.  He made fake 
business phone calls and brought his friends in for fake meetings.  After 6 
PM you're supposed to swipe a badge to get in, but luckily a security guard 
held the door for him.  He only left when they downsized almost everyone 
else on his floor -- and not because they caught on; he went around saying 
goodbye to everyone in the office and everyone wished him well.  No Web 
link, unfortunately.

150-year-old Edgar Allan Poe ciphers decrypted:
<http://www.nandotimes.com/noframes/story/0,2107,500285318-500450085-5029354 
51-0,00.html>

Very interesting talks on hacking by Richard Thieme (audio versions):
<http://www.thiemeworks.com/speak/audio.htm>

Picture recognition technology that could replace passwords:
<http://www.zdnet.com/zdnn/stories/news/0,4586,2657540,00.html>

Good article on malware:
<http://enterprise.cnet.com/enterprise/0-9567-7-3780311.html?tag=st.cn.1.tlpg>

Not nearly enough is being done to train information security experts, and 
U.S. companies face a staffing shortfall that will likely grow ever larger.
<http://www.businessweek.com/bwdaily/dnflash/nov2000/nf20001128_281.htm>

Luciano Pavarotti could not check in at his Italian hotel because he lacked 
proper identification.  When you can't even authenticate in the real world, 
how are you ever going to authenticate in cyberspace?
<http://news.excite.com/news/r/001127/07/odd-pavarotti-dc>

After receiving a $10M anonymous grant, John Hopkins University is opening 
an information security institute:
<http://www.jhu.edu/news_info/news/univ00/dec00/jhuisi.html>

Most countries have weak computer crime laws:
<http://www0.mercurycenter.com/svtech/news/breaking/merc/docs/055166.htm>

Plans for an open source operating system designed to defeat U.K.'s 
anti-privacy laws:
<http://www.m-o-o-t.org/>

Microsoft held an invitational security conference: SafeNet 2000.  Near as 
I can tell (I wasn't there; schedule conflict), there was a lot of 
posturing but no real meat.  Gates made a big deal of new cookie privacy 
features on Internet Explorer 6.0, but all it means is that Microsoft is 
finally implementing the P3P protocol...which isn't all that great 
anyway.  Microsoft made a great show of things, but talk is a lot cheaper 
than action.
<http://www.theregister.co.uk/content/4/15316.html>
<http://www.theregister.co.uk/content/archive/12102.html>
<http://www.zdnet.com/zdnn/stories/news/0,4586,2662375,00.html>
<http://www.wired.com/news/technology/0,1282,40591,00.html>

Speaking of action, Microsoft now demands that security mailing lists not 
republish details of Microsoft security vulnerabilities, citing copyright laws.
<http://www.theregister.co.uk/content/4/15337.html>


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       Counterpane Internet Security News



Counterpane receives $24M in third-round funding:
<http://www.counterpane.com/pr-funding2.html>
<http://www.crn.com/Sections/BreakingNews/dailyarchives.asp?ArticleID=21939>

Counterpane success stories:
<http://www.counterpane.com/success-exp.html>
<http://www.counterpane.com/success-conx.html>
<http://www.corio.com/news_story.cfm?news_id=161&>;

More reviews of Secrets and Lies:
<http://www.zdnet.com/pcmag/stories/opinions/0,7802,2649205,00.html>
<http://www.cio.com/archive/111500_tl_shelf_content.html>
<http://www.business2.com/content/research/reviews/2000/10/16/21009>
All reviews:
<http://www.counterpane.com/sandlrev.html>


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             Crypto-Gram News



Crypto-Gram has been nominated for an "Information Security Excellence 
Award" by Information Security Magazine, in the "On-Line Security Resource" 
catagory.  If you are a subscriber to the magazine--it's a free 
subscription--you can vote.  You will need a copy of your magazine's 
mailing label.  Voting is open until 17 January.

<http://www.cyclonecafe3.com/isawards/>

Thank you for your support.


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       IBM's New Crypto Mode of Operation



In November, IBM announced a new block-cipher mode of operation that 
"simultaneously encrypts and authenticates," using "about half the time," 
and is more suited for parallelization.  IBM's press release made bold 
predictions of the algorithm's wide use and fast acceptance.  I'd like to 
offer some cautionary notes.

Basically, the research paper proposes two block cipher modes that provide 
both encryption and authentication.  It's author Charanjit S. Jutla at the 
T.J. Watson Research Center.  This is really cool research.  It's new work, 
and proves (and shows how) integrity can be achieved for free on top of 
symmetric-key encryption.

This has some use, but I don't see an enormous market demand for this.  A 
factor of two speed improvement is largely irrelevant.  Moore's Law 
dictates that you double your speed every eighteen months, just by waiting 
for processors to improve.  AES is about three times the speed of DES and 
eight times the speed of triple-DES.  Things are getting faster all the 
time.  Much more interesting is the parallelization; it could be a real 
boon for hardware crypto accelerators for things like IPsec.

Even so, cryptographic implementations are not generally hampered by the 
inefficiency of algorithms.  Rarely is the cryptography the bottleneck in 
any communications.  Certainly using the same cryptographic primitive for 
both encryption and authentication is a nice idea, but there are many ways 
to do that.

Combining encryption with authentication is not new.  The literature has 
had algorithms that do both for years.  This research has a lot in common 
with Phillip Rogaway's OCB mode.  On the public-key side of things, Y. 
Zheng has been working on "signcryption" since 1998.

Most security protocols prefer separating encryption and 
authentication.  The original implementation of PGP, for example, used the 
same keys for encryption and authentication.  They were separated in later 
versions of the protocol.  This was done for security reasons; encryption 
and authentication are different.  The key management is different, the 
security requirements are different, and the implementation requirements 
are different.  Combining the two makes engineering harder, not 
easier.  (Think of a car pedal that both accelerates and brakes; I think we 
can agree that this is not an improvement.)

Unfortunately, IBM is patenting these modes of operation.  This makes it 
even less likely that anyone will implement it, and very unlikely that NIST 
will make it a standard.  We've lived under the RSA patents for long 
enough; no one will willingly submit themselves to another patent regime 
unless there is a clear and compelling advantage.  It's just not worth it.

IBM has a tendency of turning good cryptographic research into ridiculous 
press releases.  Two years ago (August 1998) IBM announced that the 
Cramer-Shoup algorithm was going to revolutionize cryptography.  It, too, 
had provable security.  A year before that, IBM announced to the press that 
the Atjai-Dwork algorithm was going to change the world.  Today I can think 
of zero implementations of either algorithm, even pilot 
implementations.   This is all good cryptography, but IBM's PR department 
overreaches and tries to turn them into things they are not.

IBM's announcement:
<http://www.ibm.com/news/2000/11/30.phtml>

Press coverage:
<http://www.thestandard.com/article/display/0,1151,20495,00.html>
<http://www4.zdnet.com:80/intweek/stories/news/0,4164,2659557,00.html>

The research paper:
<http://csrc.nist.gov/encryption/aes/modes/jutla-auth.pdf>

Rogaway's OCB Mode:
<http://www.cs.ucdavis.edu/~rogaway/papers/ocb.pdf>

My write-up of Cramer-Shoup:
<http://www.counterpane.com/crypto-gram-9809.html#cramer-shoup>


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            The Doghouse: Blitzkrieg



This is just too bizarre for words.  If the Doghouse had a hall of fame, 
this would be in it.

<http://vmyths.com/rant.cfm?id=213&page=4>


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       Solution in Search of a Problem:
          Digital Safe-Deposit Boxes



Digital safe-deposit boxes seem to be popping up like mushrooms, and I 
can't figure out why.  Something in the water?  Group 
disillusionment?  Whatever is happening, it doesn't make sense to me.

Look at the bank FleetBoston.  In October, they announced something called 
fileTRUST, a digital safe-deposit box.  For $11 a month, FleetBoston will 
store up to 40MB of stuff in their virtual safe deposit box.  Their press 
release reads:  "Document storage enables a business owner to expand memory 
capacity without having to upgrade hardware and guarantees that files will 
be protected from deadly viruses..."  Okay, $11 for 40MB is $0.28 per MB 
per month.  You can go down to any computer superstore and buy a 20 Gig 
drive for $120; if we assume the drive will last four years, that's $0.0001 
per MB.  Is it that difficult to add a new hard drive to a computer?  And 
the "deadly viruses" claim: storing backups offline is just as effective 
against viruses, and fileTRUST's feature that allows you to map your data 
as a network drive makes it just as vulnerable to viruses as any other 
drive on your computer.  Or if you don't map the fileTRUST archive, isn't 
the decryption key vulnerable to v
iruses?

I dismissed this as a bank having no clue how computers work, but then I 
started seeing the same idea elsewhere.  At least three other companies -- 
DigiVault, Cyber-Ark, and Zephra -- are doing essentially the same thing, 
but touting it as kind of a poor man's VPN.  You can use this virtual 
safe-deposit box as kind of a secure shared hard drive.  Presumably you can 
give different people access to different parts of this shared space, take 
access away quickly, reconfigure, etc.

The DigiVault site is the most entertaining of the bunch.  There are a lot 
of words on their pages, but no real information about what the system 
actually *does* or how it actually *works*.  Even the "Technical 
Specifications" don't actually specify anything, and instead parrot some 
security buzzwords.

First off, the safe-deposit box metaphor (Cyber-Ark calls it a "Network 
Vault: (tm)) makes no sense.  The primary value of a safe-deposit box is 
reliability.  You put something in, and it will remain there until you show 
up at the bank with your key.  That's why it's called a "safe-deposit box" 
and not a "private deposit box," although privacy is a side benefit.  The 
"digital safe-deposit box" provides privacy (insofar as the system is 
actually secure), but is just as vulnerable to denial-of-service attacks as 
any other server on the Internet.  And the box is only secure against 
actual destruction of the data insofar as they back up the data to some 
kind of media and store it somewhere.  These companies presumably make 
backups, but how often?  Where and how are the backups stored?  The Web 
sites don't bother to say.

The problem with this metaphor becomes apparent when you read the "No Time 
for a VPN?" article (second DigiVault URL).  The author says it's like a 
safe deposit box because you need two keys to open it:  the bank uses your 
public key and you use your private key.  But the point of having two keys 
to a real safe deposit box is that the bank only provides its key after you 
prove your identity; that way, someone stealing your key can't 
automatically get into your box.  It works because the bank's key is *not* 
public.  With DigiVault, the bank uses the same public key that you give to 
others so they can send stuff to your box.  In that case, what's the point 
of the bank's key?

Second, I don't understand the business model.  Yes, VPNs are hard to 
configure, but they're now embedded in firewalls and operating systems, and 
are getting easier to use.  Yes, it's nice to have a shared piece of 
digital storage, but 1) I generally use my webserver, and 2) there are 
companies like X-Drive giving this stuff away.  Once you combine encrypted 
mail with free Web storage space, you have the same functionality that a 
virtual safe-deposit box offers, for free.  Now you're competing solely on 
user interface.

A digital safe-deposit box (or whatever it should be called) might be the 
ideal product for someone.  But I just don't see enough of those someones 
to make a viable market.


fileTRUST:
<http://www.cnn.com/2000/TECH/computing/10/13/fleet.boxes.idg/>
<http://www.businesswire.com/cgi-bin/f_headline.cgi?bw.101000/202842566&tick 
er=FBF>
<http://www.boston.com/dailynews/284/economy/Fleet_to_offer_Web_based_safe_P 
.shtml>
<http://www.boston.com/dailynews/284/economy/Boston_bank_offers_Web_based_sP 
.shtml>

Others:
<http://www.mydigivault.com>
<http://www.lexias.com/TE_page1.html>
<http://www.securitymadesimple.com>
<http://www.cyber-ark.com/>


** *** ***** ******* *********** *************

         New Bank Privacy Regulations



There are some new (proposed) interagency guidelines for protecting 
customer information.  Near as I can tell, "interagency" includes the 
Office of the Comptroller of the Currency (Treasury), Board of Governors of 
the Federal Reserve System, and Office of Thrift Supervision (also 
Treasury).  If you're a bank, this is a big deal.  Ensuring the privacy of 
your customers will now be required.

Here are some highlights of the proposals:

	The Board of Directors is responsible for protection of customer 
information and data.

	The Board of Directors must receive reports on the overall status of the 
information security program, including materials related to attempted or 
actual security breaches or violations and responsive actions taken by 
management.

	Monitoring systems must be in place to detect actual and attempted attacks 
on or intrusions into customer information systems.

	Management must develop response programs that specify actions to be taken 
when unauthorized access to customer information systems is suspected or 
detected.

	Staff must be trained to recognize, respond to, and where appropriate, 
report to regulatory and law enforcement agencies, any unauthorized or 
fraudulent attempts to obtain customer information

	Management must monitor, evaluate, and adjust, as appropriate, the 
information security program in light of any relevant changes in 
technology, the sensitivity of its customer information, and internal or 
external threats to information security.

These rules are an addition to something called Regulation H.  Regulation H 
is an existing section of legal code that covers a variety of stuff, 
including the infamous "Know Your Customer" program.

Proposed rules:
<http://www.bankinfo.com/062600.txt>

Comments on the proposed rules:
<http://www.ots.treas.gov/docs/48150.html>

Some other privacy regulations that went into effect on 13 November, with 
optional compliance until 1 July 2001:
<http://www.bankinfo.com/060100.pdf>


** *** ***** ******* *********** *************

            Comments from Readers



From: Anonymous
Subject: Microsoft

You didn't hear this from me, but:

- The attackers didn't get in using QAZ.  As of last week, Microsoft still 
didn't know how they entered the network.  The media invented the QAZ 
story, and Microsoft decided not to correct them.
- The damage is much worse than anyone has speculated.


From: Anonymous
Subject: Microsoft

I was involved with Microsoft's interaction with the press over "the 
event."  What actually got told to the press was a completely *separate* 
incident than the one that really caused the problems.  The reason that 
none of the stories agreed was that they were all fiction.


From: Julian Cogdell <Julianc@rfs.co.uk>
Subject: Microsoft "set hacker trap" theory

Not quite the "penetration test by a Microsoft tiger team" you predicted in
the latest Crypto-Gram, but it's almost there....

<http://www.vnunet.com/News/1113504>


From: "Ogle Ron (Rennes)" <OgleR@thmulti.com>
Subject: Implications of the Microsoft Hack

I agree with you about this being an unprofessional job, but I wonder what 
will happen when this becomes a professional job with long-term 
objectives.  I keep thinking that the computerized world is going to have 
its Black Plague.

If someone wanted to devastate the computerized world, one way would be to 
plant code into a future release of an operating system that would be 
widely disseminated and remotely triggerable.  If an attacker were to have 
a long-term objective, she could steal the code, create 30 or 40 
vulnerabilities in several different parts of the software, and return the 
code.  Then, say in three years, the attacker could determine which 
vulnerabilities remained in the "released" software.

She would then devise ways to find the quickest and deadliest attacks while 
waiting for an additional two years for the software to become entrenched 
in the world.  At this time, she would deploy one vulnerability to show the 
world what power she could wield.  Because the vulnerabilities would be in 
several different parts of the operating system, it would be very difficult 
(i.e., near impossible) to remove these other surviving vulnerabilities or 
even defend against them.  The one exception for a defense would be to 
unplug yourself from the Internet.  I'm thinking in five years, to unplug 
yourself from the Internet for any prolonged period of time would be 
tantamount to going out of business.

The hacker would wait for two days and put out a demand for whatever she 
wanted and of course immunity from prosecution, or she would unleash the 
other vulnerabilities to the other computers that still remained on the 
Internet.  Either way, corporations are losing billions a day, and these 
corporations would put such pressure on their governments to do whatever 
was required.  Remember, if you're off the Internet to protect yourself, 
then you can't support commerce.  The nice part for the operating system 
company is that they are covered because all of these corporations are 
using "AS IS" software with no guarantees or warranties.

How is this possible?  Technically, all of the pieces are there to 
accomplish such an attack.  I believe that motive is still missing with the 
people who are technically capable.  I believe this is a reasonable 
possibility because of the following:

1.  With a little more knack, Microsoft could have been hacked without 
being detected and the attacker could have downloaded the software for a 
future release.  The attacker would also steal a few passwords to be able 
to get back in as an authorized user for the future.

2.  We have seen that people can write some very dangerous code, usually 
through viruses.  Given the source code, a person could devise very very 
dangerous code and could disguise it.  Remember that Microsoft programmers 
often embed "Easter eggs" and self-promoting code that makes it through 
their quality assurance checks.  Now to make sure that enough 
vulnerabilities survive (5 to 10) into the released version, the attacker 
would need to create 30 to 40 such vulnerabilities.

3.  Based upon the openness of the software sharing, the attacker could 
come back in with one or more of the authorized user accounts.  The 
attacker then uploads the "new" software into the code base.  Some of this 
code will be lost through normal evolution of the code base, but enough of 
the exploits should survive.

4.  We know that security is not really looked at from a quality assurance 
or testing perspective because of the sure number of vulnerabilities that 
are uncovered that should have never been there in the first 
place.  Programmers/testers are basically not very knowledgeable in good 
software engineering practices, so "bad" code doesn't affect them 
much.  Therefore, if the code works, they are likely to say good enough.

5.  Most companies support a computer infrastructure made up of mostly a MS 
Windows environment.  Because companies have this homogeneous solution, all 
of their systems would be very vulnerable to this or other types of attacks 
which would devastate their business.  This of course was seen during the 
Love Bug virus when companies with mostly MS Windows systems were brought 
to their knees.  Just as in nature, diversity is rewarded, but the computer 
world is reversed (that is, until the Black Plague!).

I think that the above scenario is definitely possible.  With the 
dependence upon MS Windows and the growing dependence upon the Internet to 
conduct business, the above attack would cause huge devastation.  The piece 
lacking to make this scenario real is a professional group or person with a 
motive that is willing to invest the time and effort for a long term 
pay-off.  Terrorist groups could have a field day with this.  The nice part 
about this is that if in the next five years the attacker decides not to go 
through with the attack, then they can just leave the vulnerabilities 
intact and nobody will be the wiser.


From: "Louis A. Mamakos" <louie@TransSys.COM>
Subject: Digital Signatures

I found your essay on "Why Digital Signatures Are Not Signatures" very 
interesting.  There's an analogue in the Real World which might help 
explain the situation.

It's the check signing machine.  It contains the "signature" of a Real 
Person, and is used to save the Real Person the drudgery of actually 
signing 5000 paychecks every couple of weeks.  Did the Real Person every 
actually see each of these documents?  Nope, but there's an expectation 
that the check signing machine is used only for authorized purposes by 
authorized personnel.  Much the same as software which computes the RSA 
algorithm to "sign" documents.

It's interesting that the use of the check signing machine probably 
wouldn't be allowed for, e.g., signing contracts.  I suppose it's all about 
expectations.


From: Douglas Davidson <drd@primenet.com>
Subject: Digital Signatures

We can perhaps gain some historical perspective on this issue by 
considering a predecessor of signatures, namely seals.  Seals are an 
ancient human invention, probably antedating writing; they have been used 
by cultures around the world for purposes similar to those that might be 
served by digital signatures:  providing evidence of the origin and 
authenticity of a document, indicating agreement, and so forth.  Seals also 
have a similar drawback:  they do not really provide evidence of the intent 
of a particular person, only of the presence of a certain object, which 
could equally well have been used by anyone who came into possession of 
it.  A common theme in the literature of cultures that use seals is their 
misuse by unauthorized persons, often close associates or family members of 
the rightful owner.  Even if you have a trusted signing computer, for which 
you can maintain complete hardware and software security, can you be 
certain that your children can't get to it?


From: Ben Wright <Ben_Wright@compuserve.com>
Subject: Digital Signatures

You are correct about the problems with digital signatures; they do not 
prove intent.  They do not perform the legal wonders claimed by their most 
zealous proponents.

But you are wrong about the new E-Sign law.  First, the law does not say 
that digital (or electronic) signatures are equivalent to handwritten 
signatures.  Laymen summarize the law that way, but strictly speaking, that 
is not what the law says.

Second, the E-Sign law does not say that digital signatures prove intent or 
anything else.  The new E-Sign law is very different from the (misguided) 
"digital signature" laws in states like Utah.

The E-Sign law is good.  It simply says that an electronic signature 
(whether based on PKI, biometrics, passwords or whatever) shall not be 
denied legal effect solely because it is electronic.  That is all it 
says.  It does not address proof of intent, proof of action or proof of 
anything else.  It does not specify technology.  It does not even mention 
digital signatures, asymmetric algorithms, public/private key systems or PKI.

See: http://ourworld.compuserve.com/homepages/Ben_Wright/e-sig.doc


From: "Herbert Neugebauer" <herbert_neugebauer@hp.com>
Subject: Digital Signatures

Your article shoots into the wrong direction.  You discredit the principle 
of digital signatures.  Your explanation, however, does not convince 
me.  The examples of why digital signatures will never be 100% safe are 
correct, but the same thing applies to real ink-on-paper signatures.  You 
partly even acknowledge in your article that there are cases in court where 
these real signatures are denied.  And these cases are sometimes won, 
sometimes lost.

Is the risk of digital signatures higher than the risk on the ink-on-paper 
signatures?  We don't know.  There are hundreds of ways to fake 
"ink-on-paper" signatures.  There are similar "ways of attacks," like 
technical attacks (fake signatures) or social attacks, attacks to lead 
people to sign a paper that contains different things than they believe 
they sign.

Some are good, others are weak and people can prove easily that they didn't 
sign or didn't want to sign or thought they actually wanted to sign 
something else.  Where's the difference to digital signatures?

I personally think the future will have to show how strong or weak the 
digital signatures actually are compared to "real" signatures.  In the 
meantime I think your article is counter-productive.  It generates 
distrust.  I think you intended to warn people that blind trust in 
technology is wrong and that just by implementing PKI and using digital 
signatures things are not automatically completely secure.  That's 
correct.  That's good.  That's important.

However the statement "These laws are a mistake.  Digital signatures are 
not signatures, and they can't fulfill their promise," is in my view plain 
wrong.  We can only judge this 10 years down the road once we really used 
the technology and can really compare how it works in comparison with 
"real" signatures.  Today digital signatures are virtually non-existent -- 
not used at all.

We should start adopting.  We have to constantly review, check, test, warn, 
revise and newly invent both technology and laws.  We should be careful, 
not be blind, but we should not dig a big hole and hide in fear of the "end 
of the world."


From: Peter Marks <macramedia@home.com>
Subject: Trusting Computers

In the latest Crypto-Gram you wrote in one context:

 > Because the computer is not trusted, I  cannot rely on
 > it to show me what it is doing or do what I tell it to.

And in another:

 > "... the computer refused to believe that the power had
 > gone off in the first place."

There's an ironic symmetry here.  Perhaps computers feel hampered by a lack 
of trusted humans.  :-)


From: jfunchion@answerthink.com (Jack Funchion)
Subject: Semantic Attacks

I have been following the discussion on semantic attacks in the Crypto-Gram 
the last two months, particularly the idea of changing old news stories in 
archives and the like.  In a previous job I worked for a company that among 
other things provided a technical analysis system for evaluating 
stocks.  It was based on a database of pricing history, and I can remember 
dreaming up an idea of how to make a killing in the stock market.  The idea 
is simply to go back and change the stock pricing data in small increments 
in the databases so that the various technical analysis equations used by 
quantitative traders will be wrong, and predictably so.  You then take 
positions opposite those predicted by the now known (by you) to be 
incorrect analyses.  I even came up with a name for this kind of attack -- 
the Saramago Subterfuge.  The name comes from Jose Saramago, Portuguese 
novelist and Nobel Literature prize winner.  He wrote a book a few years 
back called _The History of the Siege of Lisbon_ which revolves around a 
proofreader who changes a single word in a historical archive and thus 
changes the history of his country.  I recommend it for your readers.


From: Xcott Craver <sacraver@EE.Princeton.EDU>
Subject: Watermarking

I'm one of the Princeton researchers who participated in the successful 
hack of SDMI's technologies.  I read your column about SDMI with interest, 
but have a few small comments and possible objections:

 > Near as I can tell, the SDMI break does not conform to
 > the challenge rules, and the music industry might claim
 > that the SDMI schemes survived the technology.

Indeed, we have many reasons to believe the contest rules were 
overstrict.  Watermark detectors were not directly available to us, but 
kept by SDMI, who would test our music _for us_ with an overhead of at 
least a few hours, sometimes half a day.  Not only did this prevent oracle 
attacks (which real attackers will perform, almost surely,) but the oracle 
response did not tell us whether failure was due to the watermark 
surviving, or due to a decision that the music was too distorted.

Also, as you suspect, our submissions were not considered valid in the 
second round because we did not provide information about how the attacks 
worked by their deadline.

We also had reason to believe that at least one of the oracles did not 
behave as documented.  That's perhaps the least extreme way to say it.  The 
two "authentication" technologies (the other four were watermarking 
technologies) were inherently untestable; when SDMI claims that three 
technologies survived, chances are they are counting those two.

 > Even if the contest was meaningful and the technology
 > survived it, watermarking does not work.  It is
 > impossible to design a music watermarking technology
 > that cannot be removed.

Ahem.  Watermarking works just fine in other application domains, just not 
this one.  By changing the application, one can move the goal posts so that 
attacks are no longer worth anything.

Consider as an example the (digital) watermarking of currency, so that 
scanners and photocopy machines will recognize a bill and refuse to scan 
it.  This can be attacked in the usual way, but if the watermark was made 
visible rather than invisible, the standard attack of removing the mark 
becomes worthless; for without the mark, the bill appears clearly 
counterfeit to a human observer.

 > Here's a brute-force attack: play the music and re-
 > record it.  Do it multiple times and use DSP technology
 > to combine the recordings and eliminate noise.

It is not clear that this will always work for all watermarking 
techniques.  On the other hand, if you have the capability of playing and 
re-recording music, you have already foiled the watermark.

My colleague Min Wu developed a similar technique for video, which involves 
simulating transmission error by leaving out MPEG blocks, then correcting 
for those missing blocks using DSP techniques.  After enough "playing and 
re-recording" a good deal of the original data is long gone.

 > Even if watermarking works, it does not solve the
 > content-protection problem.  If a media player only
 > plays watermarked files, then copies of a file will
 > play.  If a media player refuses to play watermarked
 > files, then analog-to-digital copies will still work.

Watermarking schemes are designed to survive digital-analog-digital 
conversion.  Very robust image watermarking schemes exist which appear to 
survive printing, xeroxing, then rescanning a watermarked image.

 > Digital files intrinsically undermine the scarcity
 > model of business: replicate many copies and sell each
 > one.  Companies that find alternate ways to do
 > business, whether they be advertising funded, or
 > patronage funded, or membership funded, or whatever,
 > are likely to survive the digital economy.  The media
 > companies figured this out quickly when radio was
 > invented -- and then television -- so why are they so
 > slow to realize it this time around?

It is indeed surprising, given media companies' previous history.  Until 
the Internet (or maybe until Digital Audio Tape,) the recording industry 
seemed to view new technology as a new business opportunity.  They went 
digital over a decade ago.  Now they seem to want to sue the landscape 
itself into not changing anymore.

It is difficult to suppress the image of the crazy old miser, driven 
paranoid by fabulous wealth.  Perhaps the flimsy compact "disc," enclosed 
in a flimsy jewel box yet wrapped in so much anti-theft plastic that a 
local TV news show aired a segment on how annoying they were, reinforces 
this view.

Interestingly, a great deal of the rise of MP3s is due to the recording 
industry's shoddy technology and unsuccessful distribution of 
music.  People want music that won't skip, while we still use a 15-year-old 
medium that requires moving parts to read.  People want to find specific 
albums, that just can't find room in a physical record store.  The 
recording industry is not merely a victim of shifting landscape, but a 
major cause of it, through their own failure to act.


From: Andrew Odlyzko <amo@research.att.com>
To: Watermarking

I agree with all your points about the SDMI hacking challenge, and would 
like to add another, which, surprisingly, I don't hear people mention.  (I 
just came back from a conference in Germany on Digital Rights Management, 
and although many speakers dealt with watermarking, not one mentioned this 
problem.)  What exactly is the threat model that watermarking is supposed 
to address?  Even if you do have an iron-tight technical solution, all that 
will allow the content producer to determine is who bought the goods from a 
legitimate merchant.  If I am an honest citizen who abides by the rules, 
and my laptop loaded with honestly purchased movies is stolen, Hollywood 
might be able to tell that the pirated copies came from my hard drive, but 
are they going to hold me responsible for their losses?

 > The media companies figured this out quickly when
 > radio was invented -- and then television -- so why
 > are they so slow to realize it this time around?

I agree with you completely about the need for new business model.  (My 
talk in Germany was on "Stronger copyright protection for cyberspace: 
Desirable, inevitable, and irrelevant," and I discussed how the industry 
really needs to think more creatively about their business instead of 
threshing around hoping for secure  protection schemes.)  However, the 
claim that "[t]he media companies figured this out quickly when radio was 
invented" is definitely not correct.  It took about a decade for this 
process.  You can read about it in Susan Smulyan's book, "Selling Radio: 
The Commercialization of American Broadcasting, 1920-1934," Smithsonian 
Institution Press, 1994.


From: "Marcus J. Ranum" <mjr@nfr.com>
Subject: Window of Exposure

I finally got a chance to re-re-read your article on reducing the window of 
exposure for a vulnerability, and I'd like to make a few comments.  First 
off, I think that you've hit on a few very important ideas.  I don't know 
of a way to tie your "exposure window" charts to a real, measurable, 
metric, but if we could, that would provide invaluable information to help 
people decide on their course of action in dealing with a 
vulnerability.  There's a subtle point, which you note, that the important 
goal is to minimize the space under the curve: the number of users that are 
vulnerable at any given time.

So, you've given us a model whereby we can point and say "you are here" 
during the course of any given security flaw/response cycle.  If you look 
at Figure 2 (limit knowledge of vulnerability) the area below the curve is 
dramatically less than the area below the curve in Figure 1 (announce the 
vulnerability).  That's very significant.

Your model of how the threat of the vulnerability "decays" is also 
thought-provoking.  For an example in many of my talks I refer to the 
"rlogin -froot" bug, which was a vulnerability in AIX 3 (if I recall 
correctly) in the early '90s.  Just about a month ago, I had a system 
administrator in my class ask me for details on how to fix that particular 
problem; he's still running AIX without patches.  So, there is, indeed, a 
"tail off" factor to the curve, like you predicted.  I've seen it.

You've also missed a very important special case scenario: the one in which 
a vulnerability is found, quietly diagnosed, quietly fixed, and never 
brought to the attention of the hacking community-at-large.  In that case, 
the area under the curve is _zero_.  Nobody is threatened or hurt at 
all.  This points to a couple of things:

1) Vendors need to take security-critical quality assurance to a much 
higher level than they do.  Finding and fixing your own bugs quickly and 
quietly is the only 100% victory solution.

2) Vendors need to be able to ensure that users actually install their patches.

The latter point is critical.  I believe that within the next five years 
software will become self-updating for many applications.  Antivirus 
software and streaming media/browsers do this today.  The former does it to 
update its rules, the latter to install new bugs on your system faster and 
more easily.  But security critical products need to do the same 
thing.  Imagine installing a piece of security critical software and having 
it, at install time, ask you:

"This software has the ability to self-update in the event of critical 
functionality or security patches.  In such an event, should I:
         A) Cease functioning and notify an administrator to manually 
install an upgrade before resuming processing
         B) Continue functioning in a reduced capacity
         C) Automatically install the update and continue to function."

Providing a good automatic update service has some daunting technical 
requirements (signed code, secure distribution servers, etc.), but those 
problems are not significantly worse than the problems we face today in 
getting our users to update all their software manually.  Perhaps savvy 
vendors will realize that such service provides an opportunity to "touch" 
their customers in a positive way (good marketing) on a regular basis, as 
well as to justify software maintenance fees.  Ironically, Microsoft, who 
many hold as the great Satan of computer security, is leading the way here: 
recently the Microsoft IIS team fielded a program called HFCheck that 
automatically checks for IIS server security updates and alerts the 
user.  The first vendor that can make a believable claim to have licked 
this problem will reap potentially huge rewards.

In such an environment, a vendor could easily base their judgements on 
progress along your exposure charts.  As soon as there is a certain number 
of users at risk, it's time to push out an upgrade.  Indeed, I predict that 
in such an environment, it'll become an interesting race between the hacker 
and the vendor to see if the hacker can issue an alert before the vendor 
can draw their fangs and make them look redundant by already having 
released a patch.  I look forward to seeing this happen, since it's a 
necessary step in triggering a change in the current economy of 
vulnerability disclosure.  Under the current economy, the hackers reap real 
benefits (ego and marketing) in spite of the users they are placing at 
risk.  If they no longer reap those benefits, a significant component of 
their motivation will be gone.

Then we'll be left to deal with the individuals whose motives are purely 
malicious.


From: Anonymous
Subject: Anecdote about "open" WaveLAN networks.

I found my first "open" WaveLAN (IEEE 802.11) network by accident.  I had a 
WaveLAN card in my laptop when I visited the California office of the 
company I work for.  My first reaction to getting a working dhcp lease was 
"Great, I won't have to fiddle with cables.  But I think I need to talk to 
the local sysadmin if he has thought about security."  My happiness quickly 
changed into annoyance when I felt how slow the network was and the 
annoyance changed into surprise when while debugging the network I realized 
that XXX.com wasn't the domain name of the company I work for (as a side 
note: XXX sells crypto hardware).  I reported the incident to the local 
sysadmin and forgot about it.

When I got back to Sweden, I told about the stupidity of XXX to a few 
friends at a restaurant in downtown Stockholm.  Some time before the food 
arrived we started to discuss WaveLAN and somehow a laptop showed up on the 
table and voila! We were inside YYYinternal.com.  We knew a guy working at 
YYY, told him  about this, he told his sysadmin, the sysadmin responded 
"I'll have to talk to the firewall guy."  (I didn't know that firewalls had 
TEMPEST protection in their default configuration.)  AFAIK the network has 
been shut off.

Another month or two passed.  I was riding the bus around downtown 
Stockholm to get home after a pretty late evening and I was too tired to 
read.  I fired up my laptop and started to detect networks.  I found six or 
seven (one could have been a duplicate) during 30 minutes.

A week later a friend from Canada visited us.  He stayed at a hotel in 
central Stockholm.  He had a working network in some spots in his 
room.  Apparently it belonged to a law firm.  On the square outside the 
hotel the networks didn't work, simply because there were three of them 
fighting with each other.  When we walked around 10 blocks in central 
Stockholm we found 5 to 15 networks.

And so on...

Many of the networks we found gave us DHCP leases and good routing out to 
the internet.  Most of them were behind a firewall, but the firewall was 
"aimed" in the wrong direction; the WaveLAN was a part of the internal 
network.  We were inside private networks of telcos, law firms, investment 
companies, consulting companies, you name it.


From: "David Gamey/Markham/IBM" <dgamey@ca.ibm.com>
Subject: SSL Caching device?

I recently came across a device that appears to cache SSL!  It appears that 
it can cache pages containing personalized data.  I haven't got the full 
story, but I suspect that the HTTP request didn't contain distinguishing 
data other than an authentication cookie.

The press release:
<http://www.cacheflow.com/news/press/2000/ssl.cfm>

An explanation:
<http://www.nwfusion.com/news/tech/2000/1023tech.html>

It appears that the device works with a layer 3/4 switch and can 
transparently grab SSL connections (by port or packet content?).  The 
marketing piece tries to position it as (or like) an SSL accelerator.  It 
talks about graphics in SSL, being deployed on the network boundary and 
being transparent to the end-user.  It's setting itself up as 
man-in-the-middle.

Depending on its caching rules, implementation bugs, etc., how many 
applications will this thing screw up?  What happens if a "hacker" gets 
control of one of these things?  The idea of something getting between me 
and my bank isn't comforting.  I already go to my bank, check out the 
site/cert, then turn on JavaScript and reload.  What next?


From: Greg Guerin <glguerin@amug.org>
Subject: DCMA Anti-Circumvention

The Digital Millennium Copyright Act (DMCA) prohibits certain acts of 
circumvention, among other things.  In particular, section 1201(a)(1) 
begins: "No person shall circumvent a technological measure that 
effectively controls access to a work protected under this title."

Look at the word "effectively."  Does it mean that the technological 
measure must be effective in order to qualify under section 
1201(a)(1)?  That is, if the measure is shown to be ineffective in 
controlling access, a mere tissue-paper lock, does that measure then cease 
to be a protected technological measure?  But that means that any 
defeatable measure will lose its legal protection just by being 
defeated.  And if that's not an incentive to circumvent, I don't know what is.

Or perhaps "effectively" means "is intended to", and only the INTENT of 
protecting the work matters, not the demonstrated strength or quality of 
the measure itself.  In short, well-intentioned incompetence is a 
sufficient defense.  But then, arguably, Java byte-codes in original 
unobfuscated form might qualify as an access control measure, since they 
are not easily readable by humans and require an "anti-circumvention 
technology" known as a disassembler or decompiler in order to be perceived 
by humans.

So what does "effectively" really mean under section 1201(a)(1)?  Upon such 
fine points do great lawsuits hinge.


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CRYPTO-GRAM is written by Bruce Schneier.  Schneier is founder and CTO of 
Counterpane Internet Security Inc., the author of "Applied Cryptography," 
and an inventor of the Blowfish, Twofish, and Yarrow algorithms.  He served 
on the board of the International Association for Cryptologic Research, 
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and cryptography.

Counterpane Internet Security, Inc. is a venture-funded company bringing 
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Copyright (c) 2000 by Counterpane Internet Security, Inc.