There is an open questions for what is the longest chain algorithm.
The service could have generated a chain of 10 rotation events and withhold them, then the user publishes his rotation, and later the service publishes its entire chain.
Which one is valid?
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Damn it youre right. Ok back to the drawing board. Thank you!
Perhaps these "service" / custodial accounts should be declared as "genesis" type, and thus be deemed ineligible for backdated key rotation?