[evanwolf]

Thanks for this, Nathan. Orphaned devices pose a suite of security problems. They outlast the companies that sell them, the companies that make them, the upstream suppliers of hardware and software, the companies that service and repair them. Smart building devices and power systems can run for decades. Implanted medical devices, home health devices, and hospital systems persist longer than five years and can outlast the corporations behind them.

Please address orphaned products so that security continues with a duty by the maker to sustain safety and security beyond the life of a product or its manufacturer. This is like the requiring a sale-time deposit into an independent fund to reclaim/recycle a product's waste.

Beyond the current proposal, you might require a device's IP to be put in escrow in the event of product or corporate end-of-life, allowing customers or third-parties to take up maintenance and security. (#RightToRepair #EoL)

[SimingtonFCC]

Thanks for your response! This would be an excellent comment on the record, and implanted devices are a particularly compelling example considering cases such as Second Sight.