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Hmm, are you sure they do? Including the "PRIVATE" section? Any docs from them saying this, and clarifying whether this includes the PRIVATE section?

Because if so, that would seem to make the certs-per-domain limits not so much of a problem. If you own example.com, and have customers using sub-domains at a.example.com, b.example.com, etc -- that would seem to make example.com suitable for inclusion on the "PRIVATE" section of the list.

No?

"owners of privately-registered domains who themselves issue subdomains to mutually-untrusting parties may wish to be added to the PRIVATE section of the list... Requests for changes to the PRIVATE section must come from the domain owner."

https://publicsuffix.org/submit/

And indeed there are a few dozen random .com, .net, etc domains in the PRIVATE section. For instance `github.io` is listed there.

If that's the way for SaaS providers to get free certs from letsencrypt for their customers at customername.provider.com, I'd expect to see the listings in the PRIVATE section skyrocket.



Yes, private suffixes are included. It has already caused a spike in new PSL submissions[1].

You're right about this being rather easy to bypass, but the main goal is probably not to mitigate against abuse but rather prevent buggy automation scripts stuck in some kind of infinite loop from DDoSing them.

[1]: https://community.letsencrypt.org/t/dyndns-no-ip-managed-dns...




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