DMCA Section 1201

Main article: Digital Millennium Copyright Act

Section 1201 of the Digital Millennium Copyright Act (17 U.S.C. § 1201) makes it a federal offense to circumvent technological protection measures (TPMs) on copyrighted works & prohibits the distribution of tools designed to do so.^[1] Enacted on October 28, 1998, as part of the DMCA implementing the World Intellectual Property Organization (WIPO) Internet treaties, the provision was presented to Congress as a tool to combat digital piracy.^[2] In practice, manufacturers have used it to block independent repair, prevent interoperability with third-party products, suppress security research, & restrict digital preservation, because any device running software can be wrapped in a TPM that Section 1201 makes illegal to bypass.^[3]

Section 1201 contains three core prohibitions & draws a legal distinction between "access controls" & "copy controls" that determines how each prohibition applies.^[1]

Section 1201(a)(1) prohibits the act of circumventing a technological measure that controls access to a copyrighted work. The statute states: "No person shall circumvent a technological measure that effectively controls access to a work protected under this title."^[4]

Section 1201(a)(2) prohibits trafficking in tools, products, or services primarily designed to circumvent access controls.^[5]

Section 1201(b)(1) prohibits trafficking in tools, products, or services primarily designed to circumvent copy controls; that is, measures protecting a copyright owner's exclusive rights to reproduce or distribute a work.^[6]

A critical asymmetry exists in this structure. Congress banned both the act of circumventing access controls & the tools for doing so. For copy controls, only the tools are banned; the act of circumventing a copy control is not itself a violation.^[7] Congress designed this gap to preserve fair use for consumers who already had lawful access to a work. In practice, because the tools are banned under 1201(b), most consumers cannot circumvent copy controls either.

Access controls prevent unauthorized users from reaching a work: passwords on streaming services, encryption on DVDs, firmware authentication on devices. Copy controls prevent someone who already has access from reproducing or distributing the work: ebook copying restrictions, for example.^[1]

Congress included permanent exceptions for specific activities:^[8]

• 1201(e): Law enforcement & government intelligence activities
• 1201(f): Reverse engineering for software interoperability (requires lawful possession of the program)
• 1201(g): Good-faith encryption research
• 1201(h): Protecting minors from explicit material
• 1201(i): Circumventing TPMs that collect personal information without notice
• 1201(j): Security testing (requires system owner authorization)

The reverse engineering exception under 1201(f) is limited to achieving interoperability with other programs.^[9] The security testing exception under 1201(j) requires authorization from the system owner, which limits independent research on devices where the manufacturer controls who receives authorization.^[10]

Civil remedies under 17 U.S.C. § 1203 include injunctions, actual damages, & statutory damages of $200 to $2,500 per act of circumvention.^[11] Courts must remit damages for nonprofit libraries & educational institutions that were unaware their conduct violated the statute.

Criminal penalties under 17 U.S.C. § 1204 apply to willful violations committed for commercial advantage or private financial gain. A first offense carries fines up to $500,000 & imprisonment up to 5 years. Repeat offenses double the maximums to $1,000,000 & 10 years.^[12] Nonprofit libraries, archives, & educational institutions are exempt from criminal liability.

Courts have generally held that fair use (17 U.S.C. § 107) is not a defense to a Section 1201 violation. Because 1201 creates an anti-circumvention right independent of copyright infringement, breaking a digital lock is illegal even when the underlying purpose would qualify as fair use.^[13]

A circuit split exists on whether Section 1201 requires a "nexus" to copyright infringement. The 2nd & 9th Circuits hold that 1201(a) creates a standalone right requiring no proof of infringement (Corley; MDY Industries v. Blizzard Entertainment).^[14] The Federal, 5th, & 6th Circuits require a showing that circumvention was tied to actual copyright infringement (Chamberlain v. Skylink; Lexmark v. Static Control; MGE UPS v. GE).^[15][16][17]

In August 2024, the D.C. Circuit rejected a First Amendment challenge to Section 1201 in Green v. Department of Justice, holding that 1201 regulates conduct rather than speech & that the triennial rulemaking process is a sufficient safety valve.^[18]

The 1996 WIPO Copyright Treaty (WCT) & the WIPO Performances and Phonograms Treaty (WPPT) required signatory nations to provide legal protection against circumvention of technological protection measures.^[19] The Clinton Administration championed both treaties & urged Congress to pass implementing legislation.

Rep. Howard Coble (R-NC) introduced H.R. 2281, the "WIPO Copyright Treaties Implementation Act," on July 29, 1997. Sen. Orrin Hatch (R-UT) introduced the Senate counterpart, S. 2037.^[20] The Senate passed S. 2037 by a 99-0 roll call vote on May 14, 1998. The House passed H.R. 2281 by voice vote on August 4, 1998. President Clinton signed the bill on October 28, 1998, as Public Law 105-304.^[2]

During the legislative process, a coalition of 62 law professors warned Congress that the anti-circumvention provisions would create unprecedented "paracopyright" rules regulating conduct traditionally outside copyright law. Prof. Pamela Samuelson of UC Berkeley described the provisions as creating an entirely new property right, distinct from any existing right under the Copyright Act.^[21]

The DMCA's "grand bargain" gave content creators TPM protections while granting online service providers safe harbors under Section 512. The anti-circumvention provisions have since been applied to monopolize repair markets & block interoperability well beyond their stated purpose of stopping piracy.

Congress included a "fail-safe" mechanism in 17 U.S.C. § 1201(a)(1)(C): every three years, the U.S. Copyright Office conducts a rulemaking to grant temporary exemptions from the prohibition on circumventing access controls.^[22]

The process begins when the Register of Copyrights issues a Notice of Inquiry. The public submits petitions, followed by multiple rounds of comments & public hearings. The Register consults the National Telecommunications and Information Administration (NTIA), then recommends exemptions to the Librarian of Congress, who issues the final rule in the Federal Register.^[3]

The burden of proof falls entirely on petitioners. They must demonstrate by preponderance of evidence that Section 1201 is causing or will cause a "substantial adverse effect" on noninfringing uses of a particular class of copyrighted works.^[23]

All exemptions expire automatically after three years. Before 2018, petitioners had to rebuild the full evidentiary record from scratch every cycle. Following a 2017 Copyright Office policy study, the office introduced a simplified renewal process in 2018: if a previously granted exemption faces no meaningful opposition, it can be renewed through a shorter petition.^[24]

The most consequential limitation of the triennial rulemaking is structural. The Librarian of Congress can only exempt the act of circumvention under 1201(a)(1). The Librarian has no authority to create exemptions to the anti-trafficking provisions in 1201(a)(2) or 1201(b).^[25]

This creates what advocates call the "tools gap." A consumer may have the legal right to jailbreak a phone or bypass DRM on a medical device, but it remains a federal crime for anyone to provide the software or service needed to perform that circumvention. Unless a consumer can write their own circumvention code, the exemption is functionally useless.^[26]

The tools gap is why FULU Bounty winners cannot share their solutions in the United States. The FULU Foundation's repair bounty program pays developers $20,000 to bypass software locks on bricked devices such as Echelon exercise bikes, but distributing those tools to the public violates Section 1201.^[27][28]

The EFF, Public Knowledge, & the Library Copyright Alliance have described the rulemaking as broken. The process requires specialized legal counsel to argue against lobbying efforts backed by the Recording Industry Association of America (RIAA), the Entertainment Software Association (ESA), & the Motion Picture Association (MPA). Adam Eisgrau of the American Library Association called the rulemaking a "Rube Goldberg contraption."

In December 2005, the EFF published a report titled DMCA Triennial Rulemaking: Failing the Digital Consumer, calling a system that requires citizens to repeatedly petition the government for permission to use their own property illegitimate. The EFF boycotted the 2006 petition cycle in protest. Sen. Ron Wyden (D-OR) has stated the process cannot keep pace with technological change.

Nine rulemaking cycles have been completed since 2000.

In 2000, the first cycle granted two exemptions: lists of websites blocked by filtering software & literary works protected by malfunctioning or obsolete access controls (the "obsolete dongle" exemption).^[29]

The second cycle (2003) added ebook accessibility for the print-disabled & software preservation for obsolete formats. Requests to bypass DVD region coding & skip unskippable DVD advertisements were denied.^[30]

Phone unlocking & a security testing exemption first appeared in the third cycle (2006), responding to the Sony BMG rootkit. The EFF boycotted this cycle in protest.^[31]

The fourth cycle (2009) legalized smartphone jailbreaking for the first time & expanded DVD circumvention for educational criticism.^[32]

Controversy peaked in the fifth cycle (2012), which revoked the phone unlocking exemption for phones purchased after January 2013, arguing unlocked phones were widely available. The decision triggered a White House petition with over 114,000 signatures & led to the Unlocking Consumer Choice and Wireless Competition Act of 2014.^[33] Jailbreaking was renewed for smartphones but denied for tablets & game consoles.

The sixth cycle (2015) was the broadest rulemaking to date, covering vehicle repair (with a 12-month implementation delay), security research (with "controlled environment" & "all other laws" restrictions), game preservation for dead authentication servers, & 3D printer feedstock. John Deere argued during the hearings that farmers do not own the software on their tractors but merely receive "an implied license for the life of the vehicle."^[34]

Repair rights expanded beyond vehicles in the seventh cycle (2018) to cover smartphones, home appliances, & IoT devices. Security research restrictions were loosened & game preservation was expanded.^[24]

The eighth cycle (2021) granted a medical device repair exemption, allowed text & data mining for scholarly research, & removed the "all other laws" restriction on security research.^[35]

The ninth cycle (2024) allowed repair of commercial food preparation equipment (widely recognized as targeting the locked-down McDonald's McFlurry machines manufactured by Taylor) & access to vehicle telematics data. Remote access to preserved video games was denied after lobbying by the ESA; the Video Game History Foundation reported that 87% of classic games released before 2010 are critically endangered.^[36] An exemption for AI red-teaming was also denied; the Copyright Office stated that AI platform access barriers may not qualify as TPMs under Section 1201.^[37]

Phone & device unlocking was first granted in 2006. When the Copyright Office revoked it for newly purchased phones in 2012, public backlash forced Congress to pass the Unlocking Consumer Choice and Wireless Competition Act of 2014, which restored the exemption & uniquely allowed third-party unlocking assistance; a rare carve-out of the 1201(a)(2) trafficking ban.^[38] The exemption currently covers phones, tablets, hotspots, & wearables.^[37]

Vehicle repair was first granted in 2015, delayed 12 months, & excluded emissions-related circumvention & telematics. The tools gap means farmers risk prosecution for distributing repair software even though the act of circumvention is exempted. The 2024 cycle added vehicle telematics data access.^[39]

Security research was first granted in 2015 with restrictive conditions: research had to occur in "controlled environments" & comply with "all other laws," creating a risk that a Computer Fraud and Abuse Act (CFAA) violation could strip the DMCA exemption. Lobbying by Rapid7 & other cybersecurity groups led to the removal of the "all other laws" requirement in 2021.^[35] The permanent statutory exception under 1201(j) still requires system owner authorization.

Game preservation was first granted in 2015, allowing users to modify locally stored games to bypass dead authentication servers. Libraries & archives can jailbreak consoles for archival purposes. The Video Game History Foundation requested remote access in 2024; the ESA successfully lobbied against it.^[37]

Medical device repair was first granted in 2021, allowing bypassing of software locks for diagnosis, maintenance, & repair. The Medical Imaging & Technology Alliance (MITA) sued the Library of Congress to block the exemption. The D.C. Circuit ruled in 2024 that the Library's rulemakings are subject to judicial review under the Administrative Procedure Act (APA); the District Court upheld the exemption on its merits.^[40]

Ebook accessibility has been continuously granted since 2003, allowing circumvention of DRM for screen readers, refreshable Braille displays, & text-to-speech. The tools gap still applies: no entity can legally distribute the circumvention tools needed to make ebooks accessible.

Eight major movie studios sued Eric Corley & his publication 2600: The Hacker Quarterly for posting DeCSS, a program that decrypted the Content Scramble System (CSS) on DVDs. DeCSS was originally developed by Norwegian teenager Jon Johansen to enable DVD playback on Linux, which had no licensed DVD player.^[41]

Judge Lewis Kaplan ruled that CSS was an effective access control & that DeCSS was a circumvention tool under 1201(a)(2). He issued a permanent injunction barring Corley from posting DeCSS or linking to sites hosting it. The Second Circuit affirmed in Universal City Studios v. Corley (2001), holding that fair use is not a defense to 1201 violations & that while computer code constitutes protected speech, its functional capacity subjects it to content-neutral regulation under intermediate scrutiny.^[13]

The decision established that consumers cannot format-shift legally purchased DVDs if doing so requires breaking a digital lock.

Chamberlain manufactured garage door openers with a "rolling code" security system. Skylink sold universal remotes that could operate Chamberlain doors. Chamberlain sued under 1201(a)(2), arguing Skylink's remotes circumvented an access control on copyrighted software embedded in the opener.^[15]

The Federal Circuit ruled for Skylink, holding that Section 1201 requires a "nexus" between circumvention & copyright infringement. Because consumers owned their garage doors & were authorized to open them, Skylink's remotes did not enable copyright infringement. The court held that 1201 "prohibits only forms of access that bear a reasonable relationship to the protections that the Copyright Act otherwise affords."^[42]

The ruling protected consumers' right to buy universal remotes, replacement parts, & independent repair tools without copyright liability.

Lexmark installed authentication microchips in its laser printer toner cartridges. The printer's firmware verified the chip before accepting a cartridge. Static Control Components (SCC) reverse-engineered the chip & created a compatible replacement. Lexmark sued under 1201(a)(2).^[43]

The Sixth Circuit reversed the district court, holding that Lexmark's authentication sequence did not "effectively control access" to the copyrighted programs because anyone who bought a Lexmark printer could read the code directly from its memory. The court interpreted the 1201(f) reverse engineering exception broadly.^[44]

The Sixth Circuit's interpretation of "effectively controls access" prevented Lexmark from using Section 1201 to block compatible toner cartridge chips.^[45]

MDY created "Glider," a bot that automated gameplay in Blizzard's World of Warcraft. Blizzard implemented "Warden," an anti-cheat system that detected & blocked bots. MDY modified Glider to bypass Warden, & Blizzard sued under 1201(a)(2) & 1201(b)(1).^[14]

The Ninth Circuit held that MDY violated 1201(a)(2) by circumventing an access control but not 1201(b)(1) because using a bot did not constitute copyright infringement. The court explicitly rejected the Federal Circuit's Chamberlain nexus requirement, ruling that 1201(a) creates a standalone right independent of traditional copyright infringement.^[46]

This created a deep circuit split. By divorcing Section 1201 from copyright infringement, the Ninth Circuit enabled software developers to enforce End User License Agreements (EULAs) through digital locks, turning breach of contract into a federal DMCA violation.

ElcomSoft, a Russian company, developed the Advanced eBook Processor, which stripped DRM from Adobe ebooks. In July 2001, ElcomSoft programmer Dmitry Sklyarov presented the research at the DEF CON hacking conference in Las Vegas. At Adobe's request, the FBI arrested Sklyarov in Las Vegas.^[47]

Sklyarov was detained for approximately three weeks before being released on $50,000 bail on August 6, 2001. His travel was restricted to Northern California for five months until prosecutors dropped charges in December 2001 in exchange for his testimony against ElcomSoft. At trial, a federal jury acquitted ElcomSoft of all criminal charges, finding the prosecution failed to prove willfulness; the software was legal in Russia.^[47]

Dr. Matthew Green, a Johns Hopkins cryptographer, & Dr. Andrew "bunnie" Huang, a computer scientist and inventor, challenged Section 1201's constitutionality under the First Amendment, represented by the EFF. Green wanted to publish academic work containing circumvention code; Huang wanted to release a video-remixing tool called the NeTV2.^[18]

The D.C. Circuit rejected the facial First Amendment challenge, holding that Section 1201 primarily regulates non-expressive conduct, not protected speech, & that the triennial rulemaking process acts as a sufficient safety valve. The court declined to find that First Amendment protections for fair use invalidate Section 1201.^[48]

Under the ruling, researchers who wish to publish circumvention-related work have no First Amendment defense & must seek protection through the triennial exemption process.^[18]

After the 2021 triennial rulemaking granted an exemption for medical device repair, the Medical Imaging & Technology Alliance (MITA) sued the Library of Congress to block it, claiming the exemption compromised patient safety & violated the Administrative Procedure Act.^[40]

The D.C. Circuit ruled in 2024 that the Library of Congress's 1201 rulemakings are subject to judicial review under the APA. The District Court then evaluated the rule on its merits & upheld the exemption.^[40]

The ruling confirmed that the triennial rulemaking process produces legally binding rules subject to APA review, and that the medical device repair exemption met the statutory standard.^[40]

Manufacturers rely on Section 1201's protections to enforce practices such as feature ransom & discontinuation bricking, confident that consumers & independent technicians cannot legally bypass the software locks these practices depend on.

Apple uses software handshakes on batteries, screens, & cameras to bind replacement parts to the device's logic board through part pairing. An independent technician who installs a genuine Apple replacement part without Apple's proprietary calibration software triggers persistent warnings or loses features like FaceID & battery health monitoring. iFixit retroactively dropped the iPhone 14's repairability score from 7 to 4 because of parts pairing.^[49]

John Deere embeds firmware locks in agricultural equipment that require proprietary diagnostic software to authorize repairs. Farmers who attempt to diagnose their own tractors are locked out, forcing them to wait for authorized technicians.^[50] Some farmers have resorted to pirated Ukrainian firmware to bypass VIN-locks on Deere equipment.

The 2021 rulemaking granted a medical device repair exemption after testimony described cases where TPMs prevented equipment repairs during the COVID-19 pandemic.^[35]

Powered wheelchairs using Dynamix controllers are locked with cryptographic security dongles, preventing disabled users from calibrating or repairing their own chairs. Colorado's HB22-1031, passed in 2022, addressed this by requiring manufacturers to provide repair passwords & dongles rather than requiring users to break the lock themselves.^[51]

Section 1201 has a documented chilling effect on vulnerability disclosure. In 2001, Princeton Professor Edward Felten successfully bypassed the Secure Digital Music Initiative (SDMI) audio watermarking system in a public challenge. When his team attempted to publish their findings, the RIAA & Verance threatened DMCA litigation. Felten temporarily withdrew the paper & sued for a declaratory judgment; the industry backed down.

In 2015, researchers Charlie Miller & Chris Valasek demonstrated remote control of a Jeep Cherokee's brakes & transmission through a vulnerability in the Chrysler Uconnect system. They deliberately chose a target that did not require bypassing traditional DRM to avoid 1201 prosecution, but the threat prevented them from publishing research on more locked-down vehicles.

Security researcher Jay Radcliffe discovered lethal vulnerabilities in insulin pumps but was advised by legal counsel to restrict disclosure because analyzing the software required circumventing DRM. In 2002, HP threatened criminal prosecution against researchers at SNOsoft for publishing a vulnerability in HP's Tru64 UNIX operating system; public outrage forced HP to retract the threat.

In 2005, Sony BMG installed DRM on music CDs that functioned as a rootkit on users' computers, creating severe security vulnerabilities. Mark Russinovich discovered the XCP rootkit in October 2005. Princeton researcher J. Alex Halderman, who had independently studied Sony's earlier MediaMax DRM, delayed publishing his own findings for weeks while consulting lawyers, fearing that explaining how to remove the software would violate Section 1201.^[52]

HP's "Dynamic Security" firmware updates recognize & block third-party or refilled ink cartridges, refusing to print with non-HP cartridges.^[53] Lexmark tried to use Section 1201 to block Static Control Components from making compatible toner cartridge chips; the Sixth Circuit rejected the claim in 2004.

In 2014, Keurig implemented an anti-counterfeiting ink scanner on Keurig 2.0 K-Cup lids. Third-party pods triggered an "Oops!" error message & the machine refused to brew.

Chamberlain, manufacturer of myQ garage door openers, shut down its public API to block integration with home automation platforms like Home Assistant. Chamberlain had previously tried to use Section 1201 against Skylink for manufacturing universal garage door remotes; the Federal Circuit rejected the claim in 2004.

When game publishers shut down authentication servers, games that require online verification become permanently unplayable. Modifying a game's code to bypass the server check or emulate the server is a 1201 violation. The triennial rulemaking has granted limited exemptions for local play, but remote access for libraries & archives was denied in 2024 after ESA lobbying.^[37]

Text & data mining researchers are blocked from stripping DRM on in-copyright ebooks for computational analysis. The 2021 rulemaking granted a limited exemption for scholarly research, expanded in 2024, but the restrictions skew digital humanities research toward pre-1925 public domain works.

Ebook publishers apply TPMs that disable text-to-speech functionality & block integration with refreshable Braille displays. The Copyright Office has granted exemptions for accessibility circumvention since 2003, but the tools gap means no entity can legally distribute accessible unlocking tools. Disabled users are, in theory, required to write their own decryption software.

When the World Wide Web Consortium (W3C) standardized DRM in web browsers through Encrypted Media Extensions (EME), it rejected a covenant that would have protected developers who bypassed EME to add closed captioning or audio description tracks. Improving video accessibility by circumventing EME remains a federal offense.

Multiple bills have sought to reform Section 1201. None have passed.

Rep. Zoe Lofgren (D-CA) & Rep. Thomas Massie (R-KY) introduced the Unlocking Technology Act (H.R. 1892 in the 113th Congress, H.R. 1587 in the 114th). It would have made circumvention illegal only when tied to actual copyright infringement & legalized the distribution of tools for non-infringing uses. Both versions died in committee.^[54]

Sen. Ron Wyden (D-OR) introduced the Breaking Down Barriers to Innovation Act (S. 990, 114th Congress), with Rep. Jared Polis (D-CO) introducing the House companion H.R. 1883. It would have automatically renewed triennial exemptions & expanded protections for security research, repair, & accessibility. Both versions died in committee.^[55]

Rep. Mondaire Jones (D-NY) & Rep. Victoria Spartz (R-IN) introduced the Freedom to Repair Act (H.R. 6566, 117th Congress). It would have exempted circumvention for repair & explicitly permitted trafficking in repair tools. It died in committee.^[56]

Sen. Thom Tillis (R-NC) & Sen. Patrick Leahy (D-VT) introduced the SMART Copyright Act (S. 3880, 117th Congress), which moved in the opposite direction: it would have strengthened TPM enforcement by mandating "Standard Technical Measures" that platforms must accommodate to retain their DMCA safe harbor. Digital rights groups & library associations opposed it. It died in committee.^[57]

The only legislative success was the Unlocking Consumer Choice and Wireless Competition Act of 2014, which restored the phone unlocking exemption & allowed third-party unlocking assistance.^[38]

State law cannot override federal copyright law, so state right to repair bills work around Section 1201 by requiring manufacturers to bypass their own locks rather than authorizing consumers to do so.

Colorado's HB22-1031 (powered wheelchairs, 2022) requires manufacturers to provide the passwords & cryptographic dongles needed for repair.^[58] Oregon's SB 1596 banned part pairing entirely, prohibiting manufacturers from using software locks to disable non-OEM replacement parts; rather than authorizing circumvention, the law forces manufacturers to stop applying the TPM.

President Biden's July 2021 Executive Order on Promoting Competition directed the Federal Trade Commission (FTC) to draft rules preventing manufacturer repair restrictions.^[59] The FTC's May 2021 Nixing the Fix report acknowledged that Section 1201 is used by manufacturers to restrict aftermarket competition & repair, & pledged enforcement under the Magnuson-Moss Warranty Act.

The RIAA has spent millions annually on lobbying since 1998, consistently targeting copyright enforcement legislation including Section 1201.^[60] The ESA has consistently opposed game preservation exemptions that would allow remote access to archived titles.

The Alliance for Automotive Innovation (formerly Auto Alliance) retains contract lobbyists across states to oppose right to repair legislation. During Copyright Office hearings, the Alliance argued that allowing consumers to access their own vehicles' diagnostic software could "enable rampant piracy of copyrighted works like music and films."

A documented revolving door exists between the Copyright Office & copyright industry groups. Karyn Temple went from the RIAA's litigation department to Register of Copyrights, then to General Counsel of the MPA. Maria Pallante went from Register of Copyrights to President & CEO of the Association of American Publishers. Former Senator Chris Dodd became Chairman & CEO of the MPAA shortly after leaving the Senate.

The United States exported the DMCA's anti-circumvention framework through WIPO treaties & bilateral trade agreements.

The WIPO Copyright Treaty (Article 11) & the WIPO Performances and Phonograms Treaty (Article 18) mandate that signatory nations provide legal protection against TPM circumvention.^[61] The United States-Mexico-Canada Agreement (USMCA, Chapter 20, Article 20.H.11) cements DMCA-style civil & criminal penalties into North American trade law.^[62]

• Digital Millennium Copyright Act
• Right to repair
• Right to own
• Part pairing
• Digital rights management
• Feature ransom
• Discontinuation bricking
• Planned obsolescence
• John Deere
• Apple