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Internet Engineering Task Force (IETF)                        Y. ShefferRequest for Comments: 7457                                      PorticorCategory: Informational                                          R. HolzISSN: 2070-1721                         Technische Universitaet Muenchen                                                          P. Saint-Andre                                                                    &yet                                                           February 2015Summarizing Known Attacks on Transport Layer Security (TLS)and Datagram TLS (DTLS)Abstract   Over the last few years, there have been several serious attacks on   Transport Layer Security (TLS), including attacks on its most   commonly used ciphers and modes of operation.  This document   summarizes these attacks, with the goal of motivating generic and   protocol-specific recommendations on the usage of TLS and Datagram   TLS (DTLS).Status of This Memo   This document is not an Internet Standards Track specification; it is   published for informational purposes.   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).  Not all documents   approved by the IESG are a candidate for any level of Internet   Standard; seeSection 2 of RFC 5741.   Information about the current status of this document, any errata,   and how to provide feedback on it may be obtained athttp://www.rfc-editor.org/info/rfc7457.Sheffer, et al.               Informational                     [Page 1]

RFC 7457                       TLS Attacks                 February 2015Copyright Notice   Copyright (c) 2015 IETF Trust and the persons identified as the   document authors.  All rights reserved.   This document is subject toBCP 78 and the IETF Trust's Legal   Provisions Relating to IETF Documents   (http://trustee.ietf.org/license-info) in effect on the date of   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 Simplified BSD License text as described in Section 4.e of   the Trust Legal Provisions and are provided without warranty as   described in the Simplified BSD License.Table of Contents1. Introduction ....................................................32. Attacks on TLS ..................................................32.1. SSL Stripping ..............................................32.2. STARTTLS Command Injection Attack (CVE-2011-0411) ..........42.3. BEAST (CVE-2011-3389) ......................................42.4. Padding Oracle Attacks .....................................42.5. Attacks on RC4 .............................................52.6. Compression Attacks: CRIME, TIME, and BREACH ...............52.7. Certificate and RSA-Related Attacks ........................52.8. Theft of RSA Private Keys ..................................62.9. Diffie-Hellman Parameters ..................................62.10. Renegotiation (CVE-2009-3555) .............................62.11. Triple Handshake (CVE-2014-1295) ..........................62.12. Virtual Host Confusion ....................................72.13. Denial of Service .........................................72.14. Implementation Issues .....................................72.15. Usability .................................................83. Applicability to DTLS ...........................................84. Security Considerations .........................................85. Informative References ..........................................8   Acknowledgements ..................................................13   Authors' Addresses ................................................13Sheffer, et al.               Informational                     [Page 2]

RFC 7457                       TLS Attacks                 February 20151.  Introduction   Over the last few years, there have been several major attacks on TLS   [RFC5246], including attacks on its most commonly used ciphers and   modes of operation.  Details are given inSection 2, but a quick   summary is that both AES-CBC and RC4, which together make up for most   current usage, have been seriously attacked in the context of TLS.   This situation was one of the motivations for the creation of the UTA   working group, which was tasked with the creation of generic and   protocol-specific recommendations for the use of TLS and DTLS   [RFC6347] (unless otherwise noted underSection 3, all of the   information provided in this document applies to DTLS).   There is an old saying attributed, ironically enough, to the US   National Security Agency (NSA): "Attacks always get better; they   never get worse."  Unfortunately, that saying is true, so any   description of security attacks can only be a snapshot in time.   Therefore this document reflects our knowledge as of this writing.   It seems likely that new attacks will be discovered in the future.   For a more detailed discussion of the attacks listed here, the   interested reader is referred to [Attacks-iSec].2.  Attacks on TLS   This section lists the attacks that motivated the current   recommendations in [SECURE-TLS].  This list is not intended to be an   extensive survey of the security of TLS.   While there are widely deployed mitigations for some of the attacks   listed below, we believe that their root causes necessitate a more   systematic solution, which we have attempted to develop in   [SECURE-TLS].   When an identifier exists for an attack, we have included its Common   Vulnerabilities and Exposures (CVE) ID.  CVE [CVE] is an extensive,   industry-wide database of software vulnerabilities.2.1.  SSL Stripping   Various attacks attempt to remove the use of Secure Socket Layer /   Transport Layer Security (SSL/TLS) altogether by modifying   unencrypted protocols that request the use of TLS, specifically   modifying HTTP traffic and HTML pages as they pass on the wire.   These attacks are known collectively as "SSL Stripping" (a form of   the more generic "downgrade attack") and were first introduced by   Moxie Marlinspike [SSL-Stripping].  In the context of Web traffic,Sheffer, et al.               Informational                     [Page 3]

RFC 7457                       TLS Attacks                 February 2015   these attacks are only effective if the client initially accesses a   Web server using HTTP.  A commonly used mitigation is HTTP Strict   Transport Security (HSTS) [RFC6797].2.2.  STARTTLS Command Injection Attack (CVE-2011-0411)   Similarly, there are attacks on the transition between unprotected   and TLS-protected traffic.  A number of IETF application protocols   have used an application-level command, usually STARTTLS, to upgrade   a cleartext connection to use TLS.  Multiple implementations of   STARTTLS had a flaw where an application-layer input buffer retained   commands that were pipelined with the STARTTLS command, such that   commands received prior to TLS negotiation are executed after TLS   negotiation.  This problem is resolved by requiring the application-   level command input buffer to be empty before negotiating TLS.  Note   that this flaw lives in the application layer code and does not   impact the TLS protocol directly.   STARTTLS and similar mechanisms are vulnerable to downgrade attacks,   whereby the attacker simply removes the STARTTLS indication from the   (unprotected) request.  This cannot be mitigated unless HSTS-like   solutions are added.2.3.  BEAST (CVE-2011-3389)   The BEAST attack [BEAST] uses issues with the TLS 1.0 implementation   of Cipher Block Chaining (CBC) (that is, the predictable   initialization vector) to decrypt parts of a packet, and specifically   to decrypt HTTP cookies when HTTP is run over TLS.2.4.  Padding Oracle Attacks   A consequence of the MAC-then-encrypt design in all current versions   of TLS is the existence of padding oracle attacks [Padding-Oracle].   A recent incarnation of these attacks is the Lucky Thirteen attack   (CVE-2013-0169) [CBC-Attack], a timing side-channel attack that   allows the attacker to decrypt arbitrary ciphertext.   The Lucky Thirteen attack can be mitigated by using authenticated   encryption like AES-GCM [RFC5288] or encrypt-then-MAC [RFC7366]   instead of the TLS default of MAC-then-encrypt.   An even newer variant of the padding oracle attack, one that does not   use timing information, is the POODLE attack (CVE-2014-3566) [POODLE]   on SSL 3.0.  This attack has no known mitigation.Sheffer, et al.               Informational                     [Page 4]

RFC 7457                       TLS Attacks                 February 20152.5.  Attacks on RC4   The RC4 algorithm [RC4] has been used with TLS (and previously, SSL)   for many years.  RC4 has long been known to have a variety of   cryptographic weaknesses, e.g., [RC4-Attack-Pau], [RC4-Attack-Man],   and [RC4-Attack-FMS].  Recent cryptanalysis results [RC4-Attack-AlF]   exploit biases in the RC4 keystream to recover repeatedly encrypted   plaintexts.   These recent results are on the verge of becoming practically   exploitable; currently they require 2^26 sessions or 13x2^30   encryptions.  As a result, RC4 can no longer be seen as providing a   sufficient level of security for TLS sessions.  For further details,   the reader is referred to [CIPHER-SUITES] and the references it   cites.2.6.  Compression Attacks: CRIME, TIME, and BREACH   The CRIME attack [CRIME] (CVE-2012-4929) allows an active attacker to   decrypt ciphertext (specifically, cookies) when TLS is used with TLS-   level compression.   The TIME attack [TIME] and the later BREACH attack [BREACH] (CVE-   2013-3587, though the number has not been officially allocated) both   make similar use of HTTP-level compression to decrypt secret data   passed in the HTTP response.  We note that compression of the HTTP   message body is much more prevalent than compression at the TLS   level.   The TIME attack can be mitigated by disabling TLS compression.  We   are not aware of mitigations at the TLS protocol level to the BREACH   attack, and so application-level mitigations are needed (see   [BREACH]).  For example, implementations of HTTP that use Cross-Site   Request Forgery (CSRF) tokens will need to randomize them.  Even the   best practices and recommendations from [SECURE-TLS] are insufficient   to thwart this attack.2.7.  Certificate and RSA-Related Attacks   There have been several practical attacks on TLS when used with RSA   certificates (the most common use case).  These include   [Bleichenbacher98] and [Klima03].  While the Bleichenbacher attack   has been mitigated in TLS 1.0, the Klima attack, which relies on a   version-check oracle, is only mitigated by TLS 1.1.   The use of RSA certificates often involves exploitable timing issues   [Brumley03] (CVE-2003-0147), unless the implementation takes care to   explicitly eliminate them.Sheffer, et al.               Informational                     [Page 5]

RFC 7457                       TLS Attacks                 February 2015   A recent certificate fuzzing tool [Brubaker2014using] uncovered   numerous vulnerabilities in different TLS libraries related to   certificate validation.2.8.  Theft of RSA Private Keys   When TLS is used with most non-Diffie-Hellman cipher suites, it is   sufficient to obtain the server's private key in order to decrypt any   sessions (past and future) that were initiated with that server.   This technique is used, for example, by the popular Wireshark network   sniffer to inspect TLS-protected connections.   It is known that stolen (or otherwise obtained) private keys have   been used as part of large-scale monitoring [RFC7258] of certain   servers.   Such attacks can be mitigated by better protecting the private key,   e.g., using OS protections or dedicated hardware.  Even more   effective is the use of cipher suites that offer "forward secrecy",   the property where revealing a secret such as a private key does not   expose past or future sessions to a passive attacker.2.9.  Diffie-Hellman Parameters   TLS allows the definition of ephemeral Diffie-Hellman (DH) and   Elliptic Curve Diffie-Hellman parameters in its respective key   exchange modes.  This results in an attack detailed in   [Cross-Protocol].  Using predefined DH groups, as proposed in   [FFDHE-TLS], would mitigate this attack.   In addition, clients that do not properly verify the received   parameters are exposed to man-in-the-middle (MITM) attacks.   Unfortunately, the TLS protocol does not mandate this verification   (see [RFC6989] for analogous information for IPsec).2.10.  Renegotiation (CVE-2009-3555)   A major attack on the TLS renegotiation mechanism applies to all   current versions of the protocol.  The attack and the TLS extension   that resolves it are described in [RFC5746].2.11.  Triple Handshake (CVE-2014-1295)   The triple handshake attack [BhargavanDFPS14] enables the attacker to   cause two TLS connections to share keying material.  This leads to a   multitude of attacks, e.g., man-in-the-middle, breaking safe   renegotiation, and breaking channel binding via TLS Exporter   [RFC5705] or "tls-unique" [RFC5929].Sheffer, et al.               Informational                     [Page 6]

RFC 7457                       TLS Attacks                 February 20152.12.  Virtual Host Confusion   A recent article [Delignat14] describes a security issue whereby   SSLv3 fallback and improper handling of session caches on the server   side can be abused by an attacker to establish a malicious connection   to a virtual host other than the one originally intended and approved   by the server.  This attack is especially serious in performance   critical environments where sharing of SSLv3 session caches is very   common.2.13.  Denial of Service   Server CPU power has progressed over the years so that TLS can now be   turned on by default.  However, the risk of malicious clients and   coordinated groups of clients ("botnets") mounting denial-of-service   attacks is still very real.  TLS adds another vector for   computational attacks, since a client can easily (with little   computational effort) force the server to expend relatively large   computational work.  It is known that such attacks have in fact been   mounted.2.14.  Implementation Issues   Even when the protocol is properly specified, this does not guarantee   the security of implementations.  In fact, there are very common   issues that often plague TLS implementations.  In particular, when   integrating into higher-level protocols, TLS and its PKI-based   authentication are sometimes the source of misunderstandings and   implementation "shortcuts".  An extensive survey of these issues can   be found in [Georgiev2012].   o  Implementations might omit validation of the server certificate      altogether.  For example, this is true of the default      implementation of HTTP client libraries in Python 2 (e.g., CVE-      2013-2191).   o  Implementations might not validate the server identity.  This      validation typically amounts to matching the protocol-level server      name with the certificate's Subject Alternative Name field.  Note:      this same information is often also found in the Common Name part      of the Distinguished Name, and some validators incorrectly      retrieve it from there instead of from the Subject Alternative      Name.   o  Implementations might validate the certificate chain incorrectly      or not at all, or use an incorrect or outdated trust anchor list.Sheffer, et al.               Informational                     [Page 7]

RFC 7457                       TLS Attacks                 February 2015   An implementation attack of a different kind, one that exploits a   simple coding mistake (bounds check), is the Heartbleed attack (CVE-   2014-0160) that affected a wide swath of the Internet when it was   discovered in April 2014.2.15.  Usability   Many TLS endpoints, such as browsers and mail clients, allow the user   to explicitly accept an invalid server certificate.  This often takes   the form of a UI dialog (e.g., "do you accept this server?"), and   users have been conditioned to respond in the affirmative in order to   allow the connection to take place.   This user behavior is used by (arguably legitimate) "SSL proxies"   that decrypt and re-encrypt the TLS connection in order to enforce   local security policy.  It is also abused by attackers whose goal is   to gain access to the encrypted information.   Mitigation is complex and will probably involve a combination of   protocol mechanisms (HSTS, certificate pinning [KEY-PINNING]), and   very careful UI design.3.  Applicability to DTLS   DTLS [RFC4347] [RFC6347] is an adaptation of TLS for UDP.   With respect to the attacks described in the current document, DTLS   1.0 is equivalent to TLS 1.1.  The only exception is RC4, which is   disallowed in DTLS.  DTLS 1.2 is equivalent to TLS 1.2.4.  Security Considerations   This document describes protocol attacks in an informational manner   and in itself does not have any security implications.  Its companion   documents, especially [SECURE-TLS], certainly do.5.  Informative References   [Attacks-iSec]              Sarkar, P. and S. Fitzgerald, "Attacks on SSL, a              comprehensive study of BEAST, CRIME, TIME, BREACH, Lucky13              and RC4 biases", August 2013,              <https://www.isecpartners.com/media/106031/ssl_attacks_survey.pdf>.   [BEAST]    Rizzo, J. and T. Duong, "Browser Exploit Against SSL/TLS",              2011, <http://packetstormsecurity.com/files/105499/Browser-Exploit-Against-SSL-TLS.html>.Sheffer, et al.               Informational                     [Page 8]

RFC 7457                       TLS Attacks                 February 2015   [BREACH]   Prado, A., Harris, N., and Y. Gluck, "The BREACH Attack",              2013, <http://breachattack.com/>.   [BhargavanDFPS14]              Bhargavan, K., Delignat-Lavaud, A., Fournet, C., Pironti,              A., and P. Strub, "Triple handshakes and cookie cutters:              breaking and fixing authentication over tls", 2014,              <https://secure-resumption.com/tlsauth.pdf>.   [Bleichenbacher98]              Bleichenbacher, D., "Chosen Ciphertext Attacks Against              Protocols Based on the RSA Encryption Standard PKCS #1",              1998, <http://archiv.infsec.ethz.ch/education/fs08/secsem/Bleichenbacher98.pdf>.   [Brubaker2014using]              Brubaker, C., Jana, S., Ray, B., Khurshid, S., and V.              Shmatikov, "Using Frankencerts for Automated Adversarial              Testing of Certificate Validation in SSL/TLS              Implementations", 2014,              <https://www.cs.utexas.edu/~shmat/shmat_oak14.pdf>.   [Brumley03]              Brumley, D. and D. Boneh, "Remote Timing Attacks are              Practical", 2003,              <http://crypto.stanford.edu/~dabo/papers/ssl-timing.pdf>.   [CBC-Attack]              AlFardan, N. and K. Paterson, "Lucky Thirteen: Breaking              the TLS and DTLS Record Protocols", IEEE Symposium on              Security and Privacy, 2013, <http://www.ieee-security.org/TC/SP2013/papers/4977a526.pdf>.   [CIPHER-SUITES]              Popov, A.,"Prohibiting RC4 Cipher Suites", Work in              Progress,draft-ietf-tls-prohibiting-rc4-01, October 2014.   [CRIME]    Rizzo, J. and T. Duong, "The CRIME Attack", EKOparty              Security Conference, 2012.   [CVE]      MITRE, "Common Vulnerabilities and Exposures",              <https://cve.mitre.org/>.Sheffer, et al.               Informational                     [Page 9]

RFC 7457                       TLS Attacks                 February 2015   [Cross-Protocol]              Mavrogiannopoulos, N., Vercauteren, F., Velichkov, V., and              B. Preneel, "A cross-protocol attack on the TLS protocol",              Proceedings of the 2012 ACM Conference in Computer and              Communications Security, pages 62-72, 2012,              <http://doi.acm.org/10.1145/2382196.2382206>.   [Delignat14]              Delignat-Lavaud, A. and K. Bhargavan, "Virtual Host              Confusion: Weaknesses and Exploits", Black Hat 2014, 2014,              <https://bh.ht.vc/vhost_confusion.pdf>.   [FFDHE-TLS]              Gillmor, D., "Negotiated Finite Field Diffie-Hellman              Ephemeral Parameters for TLS", Work in Progress,draft-ietf-tls-negotiated-ff-dhe-05, December 2014.   [Georgiev2012]              Georgiev, M., Iyengar, S., Jana, S., Anubhai, R., Boneh,              D., and V. Shmatikov, "The most dangerous code in the              world: validating SSL certificates in non-browser              software", Proceedings of the 2012 ACM conference on              Computer and Communications Security, pages 38-49, 2012,              <http://doi.acm.org/10.1145/2382196.2382204>.   [KEY-PINNING]              Evans, C., Palmer, C., and R. Sleevi, "Public Key Pinning              Extension for HTTP", Work in Progress,draft-ietf-websec-key-pinning-21, October 2014.   [Klima03]  Klima, V., Pokorny, O., and T. Rosa, "Attacking RSA-based              Sessions in SSL/TLS", 2003,              <https://eprint.iacr.org/2003/052.pdf>.   [POODLE]   Moeller, B., Duong, T., and K. Kotowicz, "This POODLE              Bites: Exploiting the SSL 3.0 Fallback", September 2014,              <https://www.openssl.org/~bodo/ssl-poodle.pdf>.   [Padding-Oracle]              Vaudenay, S., "Security Flaws Induced by CBC Padding              Applications to SSL, IPSEC, WTLS...", EUROCRYPT 2002,              2002, <http://www.iacr.org/cryptodb/archive/2002/EUROCRYPT/2850/2850.pdf>.   [RC4]      Schneier, B., "Applied Cryptography: Protocols,              Algorithms, and Source Code in C", Second Edition, October              1996.Sheffer, et al.               Informational                    [Page 10]

RFC 7457                       TLS Attacks                 February 2015   [RC4-Attack-AlF]              AlFardan, N., Bernstein, D., Paterson, K., Poettering, B.,              and J. Schuldt, "On the Security of RC4 in TLS", Usenix              Security Symposium 2013, August 2013,              <https://www.usenix.org/conference/usenixsecurity13/security-rc4-tls>.   [RC4-Attack-FMS]              Fluhrer, S., Mantin, I., and A. Shamir, "Weaknesses in the              Key Scheduling Algorithm of RC4", Selected Areas in              Cryptography, August 2001,              <http://www.crypto.com/papers/others/rc4_ksaproc.pdf>.   [RC4-Attack-Man]              Mantin, I. and A. Shamir, "A Practical Attack on Broadcast              RC4", April 2001,              <http://saluc.engr.uconn.edu/refs/stream_cipher/mantin01attackRC4.pdf>.   [RC4-Attack-Pau]              Paul, G. and S. Maitra, "Permutation After RC4 Key              Scheduling Reveals the Secret Key", August 2007,              <http://dblp.uni-trier.de/db/conf/sacrypt/sacrypt2007.html#PaulM07>.   [RFC4347]  Rescorla, E. and N. Modadugu, "Datagram Transport Layer              Security",RFC 4347, April 2006,              <http://www.rfc-editor.org/info/rfc4347>.   [RFC5246]  Dierks, T. and E. Rescorla, "The Transport Layer Security              (TLS) Protocol Version 1.2",RFC 5246, August 2008,              <http://www.rfc-editor.org/info/rfc5246>.   [RFC5288]  Salowey, J., Choudhury, A., and D. McGrew, "AES Galois              Counter Mode (GCM) Cipher Suites for TLS",RFC 5288,              August 2008, <http://www.rfc-editor.org/info/rfc5288>.   [RFC5705]  Rescorla, E., "Keying Material Exporters for Transport              Layer Security (TLS)",RFC 5705, March 2010,              <http://www.rfc-editor.org/info/rfc5705>.   [RFC5746]  Rescorla, E., Ray, M., Dispensa, S., and N. Oskov,              "Transport Layer Security (TLS) Renegotiation Indication              Extension",RFC 5746, February 2010,              <http://www.rfc-editor.org/info/rfc5746>.Sheffer, et al.               Informational                    [Page 11]

RFC 7457                       TLS Attacks                 February 2015   [RFC5929]  Altman, J., Williams, N., and L. Zhu, "Channel Bindings              for TLS",RFC 5929, July 2010,              <http://www.rfc-editor.org/info/rfc5929>.   [RFC6347]  Rescorla, E. and N. Modadugu, "Datagram Transport Layer              Security Version 1.2",RFC 6347, January 2012,              <http://www.rfc-editor.org/info/rfc6347>.   [RFC6797]  Hodges, J., Jackson, C., and A. Barth, "HTTP Strict              Transport Security (HSTS)",RFC 6797, November 2012,              <http://www.rfc-editor.org/info/rfc6797>.   [RFC6989]  Sheffer, Y. and S. Fluhrer, "Additional Diffie-Hellman              Tests for the Internet Key Exchange Protocol Version 2              (IKEv2)",RFC 6989, July 2013,              <http://www.rfc-editor.org/info/rfc6989>.   [RFC7258]  Farrell, S. and H. Tschofenig, "Pervasive Monitoring Is an              Attack",BCP 188,RFC 7258, May 2014,              <http://www.rfc-editor.org/info/rfc7258>.   [RFC7366]  Gutmann, P., "Encrypt-then-MAC for Transport Layer              Security (TLS) and Datagram Transport Layer Security              (DTLS)",RFC 7366, September 2014,              <http://www.rfc-editor.org/info/rfc7366>.   [SECURE-TLS]              Sheffer, Y., Holz, R., and P. Saint-Andre,              "Recommendations for Secure Use of TLS and DTLS", Work in              Progress,draft-ietf-uta-tls-bcp-08, December 2014.   [SSL-Stripping]              Marlinspike, M., "sslstrip", February 2009,              <http://www.thoughtcrime.org/software/sslstrip/>.   [TIME]     Be'ery, T. and A. Shulman, "A Perfect CRIME? Only TIME              Will Tell", Black Hat Europe 2013, 2013,              <https://media.blackhat.com/eu-13/briefings/Beery/bh-eu-13-a-perfect-crime-beery-wp.pdf>.Sheffer, et al.               Informational                    [Page 12]

RFC 7457                       TLS Attacks                 February 2015Acknowledgements   We would like to thank Stephen Farrell, Simon Josefsson, John   Mattsson, Yoav Nir, Kenny Paterson, Patrick Pelletier, Tom Ritter,   Rich Salz, and Meral Shirazipour for their feedback on this document.   We thank Andrei Popov for contributing text on RC4, Kohei Kasamatsu   for text on Lucky13, Ilari Liusvaara for text on attacks and on DTLS,   Aaron Zauner for text on virtual host confusion, and Chris Newman for   text on STARTTLS command injection.  Ralph Holz gratefully   acknowledges the support of NICTA (National ICT of Australia) in the   preparation of this document.   During IESG review, Richard Barnes, Barry Leiba, and Kathleen   Moriarty caught several issues that needed to be addressed.   The authors gratefully acknowledge the assistance of Leif Johansson   and Orit Levin as the working group chairs and Pete Resnick as the   sponsoring Area Director.   The document was prepared using the lyx2rfc tool, created by Nico   Williams.Authors' Addresses   Yaron Sheffer   Porticor   29 HaHarash St.   Hod HaSharon  4501303   Israel   EMail: yaronf.ietf@gmail.com   Ralph Holz   Technische Universitaet Muenchen   Boltzmannstr. 3   Garching  85748   Germany   EMail: holz@net.in.tum.de   Peter Saint-Andre   &yet   EMail: peter@andyet.com   URI:https://andyet.com/Sheffer, et al.               Informational                    [Page 13]