User:Louis/Alliance for Automotive Innovation and Section 1201: Difference between revisions
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At the April 18, 2024 Section 1201 hearing on proposed Class 7, Alliance for Automotive Innovation counsel Mark Humphrey argued that an exemption for vehicle telematics data was unnecessary because the auto industry had already made that data available through the 2014 Memorandum of Understanding and the 2023 Data-Sharing Commitment.<ref name="transcript" /> | At the April 18, 2024 Section 1201 hearing on proposed Class 7, Alliance for Automotive Innovation counsel Mark Humphrey argued that an exemption for vehicle telematics data was unnecessary because the auto industry had already made that data available through the 2014 Memorandum of Understanding and the 2023 Data-Sharing Commitment.<ref name="transcript" /> Auto Care Association counsel Lisa Foshee testified that the 2014 MOU exempts telematics data on its own terms, the 2023 commitment is voluntary and was signed by only two aftermarket groups plus the Alliance itself, and six automakers told the GAO they give their own dealerships no telematics access at all.<ref name="transcript" /><ref name="gao" /><ref name="commit2023" /> On October 28, 2024, six months after the hearing, the Copyright Office granted the Class 7 exemption it had been told was unnecessary, codified at 37 CFR 201.40(b)(14).<ref name="fr2024" /> | ||
The Alliance for Automotive Innovation (also styled Auto Innovators or AAI) is the trade association representing most automakers selling in the United States. | The Alliance for Automotive Innovation (also styled Auto Innovators or AAI) is the trade association representing most automakers selling in the United States. | ||
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== What the Alliance for Automotive Innovation argued == | == What the Alliance for Automotive Innovation argued == | ||
[[File:AAI-1201-humphrey-mou-claim.png|thumb|center|upright=2.4| | [[File:AAI-1201-humphrey-mou-claim.png|thumb|center|upright=2.4|Mark Humphrey, counsel for the Alliance for Automotive Innovation, at the April 18, 2024 Section 1201 Class 7 hearing.<ref name="transcript" />]] | ||
Mark Humphrey appeared as counsel for the Alliance for Automotive Innovation.<ref name="transcript" /><ref name="video" /> His core position was that the proposed Class 7 exemption was unnecessary because the data was already available. He told the panel ''the auto industry has taken great steps to make this kind of data available through the Memorandum of Understanding from 2014 and the Data-Sharing Commitment that was entered into just last year.''<ref name="transcript" /> | Mark Humphrey appeared as counsel for the Alliance for Automotive Innovation.<ref name="transcript" /><ref name="video" /> His core position was that the proposed Class 7 exemption was unnecessary because the data was already available. He told the panel ''the auto industry has taken great steps to make this kind of data available through the Memorandum of Understanding from 2014 and the Data-Sharing Commitment that was entered into just last year.''<ref name="transcript" /> | ||
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He argued that independent shops could already get the data through several routes, listing data-repository websites, aftermarket scan tools, and remote diagnostic support.<ref name="transcript" /> He told the panel that ''independent repair facilities are able to obtain that data through multiple means.''<ref name="transcript" /> | He argued that independent shops could already get the data through several routes, listing data-repository websites, aftermarket scan tools, and remote diagnostic support.<ref name="transcript" /> He told the panel that ''independent repair facilities are able to obtain that data through multiple means.''<ref name="transcript" /> | ||
[[File:AAI-1201-humphrey-glowingly-claim.png|thumb|center|upright=2.4| | [[File:AAI-1201-humphrey-glowingly-claim.png|thumb|center|upright=2.4|Humphrey's claim at the April 18, 2024 hearing that the FTC and DOJ joint comment praised the auto industry's data-sharing record.<ref name="transcript" />]] | ||
On the regulators, Humphrey said a joint filing by the FTC and the DOJ ''spoke glowingly of the auto industry as a standard to aspire to, because of the lengths that the industry has gone to provide this kind of data,'' and later that ''the DOJ/FTC report specifically says that the auto industry is probably leading the way in this.''<ref name="transcript" /> | On the regulators, Humphrey said a joint filing by the FTC and the DOJ ''spoke glowingly of the auto industry as a standard to aspire to, because of the lengths that the industry has gone to provide this kind of data,'' and later that ''the DOJ/FTC report specifically says that the auto industry is probably leading the way in this.''<ref name="transcript" /> | ||
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Lisa Foshee, senior vice president and general counsel of the Auto Care Association, answered Humphrey on the record. She testified that ''The 2014 MOU exempts telematics data. The ASA Pact or the Data-Sharing Agreement tries to window dress the inclusion of telematics, but it only includes telematics data that is not otherwise available via the OBD2 port in the car.''<ref name="transcript" /> | Lisa Foshee, senior vice president and general counsel of the Auto Care Association, answered Humphrey on the record. She testified that ''The 2014 MOU exempts telematics data. The ASA Pact or the Data-Sharing Agreement tries to window dress the inclusion of telematics, but it only includes telematics data that is not otherwise available via the OBD2 port in the car.''<ref name="transcript" /> | ||
[[File:AAI-1201-foshee-mou-exempts-telematics.png|thumb|center|upright=2.4|Auto Care Association general counsel Lisa Foshee | [[File:AAI-1201-foshee-mou-exempts-telematics.png|thumb|center|upright=2.4|Auto Care Association senior vice president and general counsel Lisa Foshee testifying at the April 18, 2024 Section 1201 Class 7 hearing.<ref name="transcript" />]] | ||
The 2023 commitment text confirms the carve-out. Disclosure of telematics data is gated behind three stacked conditions, all required before any duty arises. The commitment promises that data only ''To the extent that specific telematic diagnostic and repair data is needed to complete a repair, and also provided to an automaker's authorized dealers, the automaker shall make such information available to vehicle owners and independent repair facilities, if it is not otherwise available through a tool or third-party service information provider.''<ref name="commit2023" /> | The 2023 commitment text confirms the carve-out. Disclosure of telematics data is gated behind three stacked conditions, all required before any duty arises. The commitment promises that data only ''To the extent that specific telematic diagnostic and repair data is needed to complete a repair, and also provided to an automaker's authorized dealers, the automaker shall make such information available to vehicle owners and independent repair facilities, if it is not otherwise available through a tool or third-party service information provider.''<ref name="commit2023" /> By its terms the duty to share attaches only to telematics data the automaker also provides to its own authorized dealers.<ref name="commit2023" /> | ||
[[File:AAI-1201-commit-telematics-carveout.png|thumb|center|upright=2.4|The | [[File:AAI-1201-commit-telematics-carveout.png|thumb|center|upright=2.4|The telematics carve-out language in the July 2023 National Automotive Repair Data Sharing Commitment.<ref name="commit2023" />]] | ||
The GAO recorded how many automakers route telematics data to their own dealers. Its March 2024 report states that ''Six automakers we interviewed told us they do not provide dealerships with any access to telematics data.''<ref name="gao" /> | The GAO recorded how many automakers route telematics data to their own dealers. Its March 2024 report states that ''Six automakers we interviewed told us they do not provide dealerships with any access to telematics data.''<ref name="gao" /> | ||
[[File:AAI-1201-gao-no-dealer-access.png|thumb|center|upright=2.4| | [[File:AAI-1201-gao-no-dealer-access.png|thumb|center|upright=2.4|GAO-24-106633 (March 2024), the page recording automakers' dealer telematics access practices.<ref name="gao" />]] | ||
On enforceability, the GAO reported that ''Specifically, because those agreements are voluntary, stakeholders worried that automakers may stop providing access to the information, data, and tools needed for repair. To the extent that happens, independent repair shops may be limited in their ability to conduct some repairs.''<ref name="gao" /> | On enforceability, the GAO reported that ''Specifically, because those agreements are voluntary, stakeholders worried that automakers may stop providing access to the information, data, and tools needed for repair. To the extent that happens, independent repair shops may be limited in their ability to conduct some repairs.''<ref name="gao" /> | ||
[[File:AAI-1201-gao-enforceability.png|thumb|center|upright=2.4| | [[File:AAI-1201-gao-enforceability.png|thumb|center|upright=2.4|GAO-24-106633, the passage recording independent repair stakeholders' enforceability concerns about the 2014 MOU and 2023 commitment.<ref name="gao" />]] | ||
=== The 2023 Data-Sharing Commitment is unenforceable and narrow === | === The 2023 Data-Sharing Commitment is unenforceable and narrow === | ||
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Foshee testified that the agreements ''are voluntary. They are non-binding. There's no enforcement mechanism.''<ref name="transcript" /> The GAO recorded the same concern, reporting that ''However, eight of the 14 independent repair stakeholders we interviewed expressed concerns about lack of enforceability in the 2014 Memorandum and 2023 commitment.''<ref name="gao" /> | Foshee testified that the agreements ''are voluntary. They are non-binding. There's no enforcement mechanism.''<ref name="transcript" /> The GAO recorded the same concern, reporting that ''However, eight of the 14 independent repair stakeholders we interviewed expressed concerns about lack of enforceability in the 2014 Memorandum and 2023 commitment.''<ref name="gao" /> | ||
[[File:AAI-1201-foshee-voluntary-nonbinding.png|thumb|center|upright=2.4| | [[File:AAI-1201-foshee-voluntary-nonbinding.png|thumb|center|upright=2.4|Foshee's testimony on the enforceability of the 2014 MOU and the 2023 commitment.<ref name="transcript" />]] | ||
On how much of the market the signing groups represent, Foshee told the hearing that ''ASA represents less than two percent of the independent shops in the United States,'' and noted that ASA ''is in large part funded by the OEs ... most of the OEs are members of ASA. So it's really sort of an agreement with themselves.''<ref name="transcript" /> The Motor & Equipment Manufacturers Association makes a related point with a different denominator. MEMA states the agreements ''contain no enforcement mechanism, lack the necessary consumer choice protections, and in the case of the 2023 agreement, represent just one percent of aftermarket repair shops.''<ref name="mema" /> The two figures are not the same measure: Foshee's ''less than two percent'' is ASA's share of independent shops on the federal-agency record, and MEMA's ''one percent'' is the signatories' share of aftermarket repair shops as an advocacy estimate. | On how much of the market the signing groups represent, Foshee told the hearing that ''ASA represents less than two percent of the independent shops in the United States,'' and noted that ASA ''is in large part funded by the OEs ... most of the OEs are members of ASA. So it's really sort of an agreement with themselves.''<ref name="transcript" /> The Motor & Equipment Manufacturers Association makes a related point with a different denominator. MEMA states the agreements ''contain no enforcement mechanism, lack the necessary consumer choice protections, and in the case of the 2023 agreement, represent just one percent of aftermarket repair shops.''<ref name="mema" /> The two figures are not the same measure: Foshee's ''less than two percent'' is ASA's share of independent shops on the federal-agency record, and MEMA's ''one percent'' is the signatories' share of aftermarket repair shops as an advocacy estimate. | ||
[[File:AAI-1201-foshee-two-percent.png|thumb|center|upright=2.4| | [[File:AAI-1201-foshee-two-percent.png|thumb|center|upright=2.4|Foshee's testimony on ASA's share of the independent repair market and its relationship with automakers.<ref name="transcript" />]] | ||
=== Independent shops do not have equal data access === | === Independent shops do not have equal data access === | ||
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The GAO recorded the resulting disadvantage. It reported that ''In addition, a disparity in access to telematics data compared to dealerships could put independent repair shops at a competitive disadvantage. These potential effects could increase prices for consumers as well as affect consumers in other ways.''<ref name="gao" /> | The GAO recorded the resulting disadvantage. It reported that ''In addition, a disparity in access to telematics data compared to dealerships could put independent repair shops at a competitive disadvantage. These potential effects could increase prices for consumers as well as affect consumers in other ways.''<ref name="gao" /> | ||
[[File:AAI-1201-gao-consumer-harm.png|thumb|center|upright=2.4| | [[File:AAI-1201-gao-consumer-harm.png|thumb|center|upright=2.4|GAO-24-106633, the passage on competitive disadvantage for independent repair shops.<ref name="gao" />]] | ||
The GAO | The GAO identified three specific disadvantage areas: remote diagnosis, marketing, and over-the-air updates.<ref name="gao" /> | ||
=== The FTC and DOJ joint comment urged granting the exemption === | === The FTC and DOJ joint comment urged granting the exemption === | ||
Humphrey told the panel the FTC and DOJ joint comment ''spoke glowingly of the auto industry as a standard to aspire to'' and was ''probably leading the way.''<ref name="transcript" /> The joint comment | Humphrey told the panel the FTC and DOJ joint comment ''spoke glowingly of the auto industry as a standard to aspire to'' and was ''probably leading the way.''<ref name="transcript" /> The joint comment asks the Copyright Office to grant the Class 7 exemption, and describes restricting telematics access as a competitively harmful bottleneck. | ||
The DOJ Antitrust Division and the FTC wrote: | The DOJ Antitrust Division and the FTC wrote: | ||
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<gallery mode="packed" heights="200"> | <gallery mode="packed" heights="200"> | ||
AAI-1201-joint-bottleneck.png|The joint comment of the DOJ Antitrust Division and the FTC warned that restricting access to non-copyrightable telematics data ''risks establishing a competitively harmful bottleneck'' for aftermarket repair.<ref name="joint" /> | AAI-1201-joint-bottleneck.png|The joint comment of the DOJ Antitrust Division and the FTC warned that restricting access to non-copyrightable telematics data ''risks establishing a competitively harmful bottleneck'' for aftermarket repair.<ref name="joint" /> | ||
AAI-1201-joint-grant-class7.png| | AAI-1201-joint-grant-class7.png|The DOJ and FTC conclusion urging the Copyright Office to grant the Class 7 exemption.<ref name="joint" /> | ||
</gallery> | </gallery> | ||
The joint comment mentions the auto sector once, and only to rebut a safety argument, writing that ''manufacturers' safety arguments are difficult to square with the automotive sector, where owners and independent repair shops are routinely able to repair highly complex products that could cause great harm if improperly repaired.''<ref name="joint" /> The words ''glowingly,'' ''standard to aspire to,'' and ''leading the way'' do not appear in the joint comment, and neither the 2014 MOU nor the 2023 commitment is mentioned in it.<ref name="joint" /> | The joint comment mentions the auto sector once, and only to rebut a safety argument, writing that ''manufacturers' safety arguments are difficult to square with the automotive sector, where owners and independent repair shops are routinely able to repair highly complex products that could cause great harm if improperly repaired.''<ref name="joint" /> The words ''glowingly,'' ''standard to aspire to,'' and ''leading the way'' do not appear in the joint comment, and neither the 2014 MOU nor the 2023 commitment is mentioned in it.<ref name="joint" /> | ||
The FTC's May 2021 report ''Nixing the Fix'' | The FTC's May 2021 report ''Nixing the Fix'' found that ''Based on a review of comments submitted and materials presented during the Workshop, there is scant evidence to support manufacturers' justifications for repair restrictions.''<ref name="nixing" /> | ||
[[File:AAI-1201-ftc-scant-evidence.png|thumb|center|upright=2.4|The FTC report ''Nixing the Fix'' | [[File:AAI-1201-ftc-scant-evidence.png|thumb|center|upright=2.4|The FTC's May 2021 report ''Nixing the Fix,'' the passage on manufacturers' justifications for repair restrictions.<ref name="nixing" />]] | ||
On the auto MOU specifically, the report recorded an outside view that it does not reach telematics, writing that ''For example, Aaron Lowe explained at the Workshop that the automobile MOU, while initially a sufficiently comprehensive agreement, does not necessarily extend in its current form to telematics.''<ref name="nixing" /> Where the report calls the MOU ''a model of self-regulation that could apply in the broader right to repair context,'' the framing is passive and attributed to outside commenters rather than stated as the FTC's own endorsement.<ref name="nixing" /> | On the auto MOU specifically, the report recorded an outside view that it does not reach telematics, writing that ''For example, Aaron Lowe explained at the Workshop that the automobile MOU, while initially a sufficiently comprehensive agreement, does not necessarily extend in its current form to telematics.''<ref name="nixing" /> Where the report calls the MOU ''a model of self-regulation that could apply in the broader right to repair context,'' the framing is passive and attributed to outside commenters rather than stated as the FTC's own endorsement.<ref name="nixing" /> | ||
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=== There is evidence of real harm === | === There is evidence of real harm === | ||
Foshee | Lisa Foshee testified that ''the Auto Care Association recently released a survey ... that showed that nationwide 84 percent of independent shops consider access to this data in this sphere ... their number one issue, and that ... over half of the shops who responded to the survey send up to five vehicles per month to dealerships because of vehicle data restrictions, because they can't fix them.''<ref name="transcript" /> | ||
[[File:AAI-1201-foshee-survey-testimony.png|thumb|center|upright=2.4| | [[File:AAI-1201-foshee-survey-testimony.png|thumb|center|upright=2.4|Foshee's testimony at the April 18, 2024 hearing citing the Auto Care Association's April 2024 independent shop survey.<ref name="transcript" />]] | ||
The underlying survey, released April 10, 2024, found that 84 percent of independent repair shops rank vehicle data access as their top business issue, 63 percent report difficulty accessing the data daily or weekly, and 51 percent send up to five vehicles a month to dealers because of data restrictions.<ref name="autocare-survey" /> | The underlying survey, released April 10, 2024, found that 84 percent of independent repair shops rank vehicle data access as their top business issue, 63 percent report difficulty accessing the data daily or weekly, and 51 percent send up to five vehicles a month to dealers because of data restrictions.<ref name="autocare-survey" /> | ||
[[File:AAI-1201-autocare-survey-84.png|thumb|center|upright=2.4| | [[File:AAI-1201-autocare-survey-84.png|thumb|center|upright=2.4|The Auto Care Association's April 2024 survey of independent repair shops on vehicle data access.<ref name="autocare-survey" />]] | ||
The GAO reported that the harm is not evenly distributed. According to five independent repair shops and independent repair associations the agency interviewed, ''The potential negative effects of reduced consumer choice may not be felt equally among all vehicle owners. For example, low-income or rural consumers could be harmed the most.''<ref name="gao" /> | The GAO reported that the harm is not evenly distributed. According to five independent repair shops and independent repair associations the agency interviewed, ''The potential negative effects of reduced consumer choice may not be felt equally among all vehicle owners. For example, low-income or rural consumers could be harmed the most.''<ref name="gao" /> | ||
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Voters have backed telematics right-to-repair laws by wide margins. Massachusetts approved the 2020 telematics ballot question, Question 1, by 2,599,182 yes votes to 867,674 no votes, about 75 percent of votes cast on the question.<ref name="ma2020" /> The same state had approved an earlier right-to-repair question in 2012, Question 1, by 2,353,603 to 392,562, about 86 percent.<ref name="ma2012" /> Maine approved its 2023 telematics question, Question 4, by 341,574 to 63,208, about 84 percent.<ref name="maine2023" /> | Voters have backed telematics right-to-repair laws by wide margins. Massachusetts approved the 2020 telematics ballot question, Question 1, by 2,599,182 yes votes to 867,674 no votes, about 75 percent of votes cast on the question.<ref name="ma2020" /> The same state had approved an earlier right-to-repair question in 2012, Question 1, by 2,353,603 to 392,562, about 86 percent.<ref name="ma2012" /> Maine approved its 2023 telematics question, Question 4, by 341,574 to 63,208, about 84 percent.<ref name="maine2023" /> | ||
[[File:AAI-1201-ma-question1-2020.png|thumb|center|upright=2.4|Massachusetts | [[File:AAI-1201-ma-question1-2020.png|thumb|center|upright=2.4|Official Massachusetts results for the 2020 right-to-repair telematics ballot question, Question 1.<ref name="ma2020" />]] | ||
After Massachusetts enforced its 2020 law, some automakers turned off connected features rather than provide equal access. NBC10 Boston reported in November 2023 that ''some of the automakers, in order to escape the requirements of the law, have turned off their internet connectivity features altogether,'' and that ''Massachusetts residents purchasing new Subarus no longer have the Starlink option.''<ref name="nbc" /> | After Massachusetts enforced its 2020 law, some automakers turned off connected features rather than provide equal access. NBC10 Boston reported in November 2023 that ''some of the automakers, in order to escape the requirements of the law, have turned off their internet connectivity features altogether,'' and that ''Massachusetts residents purchasing new Subarus no longer have the Starlink option.''<ref name="nbc" /> | ||
[[File:AAI-1201-nbc-starlink-disabled.png|thumb|center|upright=2.4|NBC10 Boston | [[File:AAI-1201-nbc-starlink-disabled.png|thumb|center|upright=2.4|NBC10 Boston's November 2023 report on automakers disabling connectivity under the Massachusetts right-to-repair law.<ref name="nbc" />]] | ||
The Massachusetts Attorney General made the same point in litigation. In ''Alliance for Automotive Innovation v. Healey'', No. 1:20-cv-12090-DPW (D. Mass.), the Attorney General argued that Subaru and Kia disabled telematics in model-year 2022 vehicles sold in Massachusetts rather than provide equal access, which the office presented as evidence that compliance with the state law was achievable.<ref name="docket" /><ref name="globe" /> That argument is the Attorney General's litigation position. | The Massachusetts Attorney General made the same point in litigation. In ''Alliance for Automotive Innovation v. Healey'', No. 1:20-cv-12090-DPW (D. Mass.), the Attorney General argued that Subaru and Kia disabled telematics in model-year 2022 vehicles sold in Massachusetts rather than provide equal access, which the office presented as evidence that compliance with the state law was achievable.<ref name="docket" /><ref name="globe" /> That argument is the Attorney General's litigation position. | ||
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<ref name="video">{{Cite web |author=U.S. Copyright Office |title=Ninth Triennial Section 1201 Public Hearings, Proposed Class 7, April 18, 2024 (Part 3) |website=YouTube |publisher=U.S. Copyright Office |date=2024-04-18 |url=https://youtu.be/6lbIRnngIBU |access-date=2026-06-12}}</ref> | <ref name="video">{{Cite web |author=U.S. Copyright Office |title=Ninth Triennial Section 1201 Public Hearings, Proposed Class 7, April 18, 2024 (Part 3) |website=YouTube |publisher=U.S. Copyright Office |date=2024-04-18 |url=https://youtu.be/6lbIRnngIBU |access-date=2026-06-12}}</ref> | ||
<ref name="gao">{{Cite web |author=U.S. Government Accountability Office |title=Vehicle Repair: Information on Evolving Vehicle Technologies and Consumer Choice (GAO-24-106633) |publisher=U.S. Government Accountability Office |date=2024-03-21 |url=https://www.gao.gov/products/gao-24-106633 |access-date=2026-06-12}}</ref> | <ref name="gao">{{Cite web |author=U.S. Government Accountability Office |title=Vehicle Repair: Information on Evolving Vehicle Technologies and Consumer Choice (GAO-24-106633) |publisher=U.S. Government Accountability Office |date=2024-03-21 |url=https://www.gao.gov/products/gao-24-106633 |access-date=2026-06-12}}</ref> | ||
<ref name="commit2023">{{Cite web |author=Alliance for Automotive Innovation |title=National Automotive Repair Data Sharing Commitment |publisher=Alliance for Automotive Innovation |date=2023 | <ref name="commit2023">{{Cite web |author=Alliance for Automotive Innovation |title=National Automotive Repair Data Sharing Commitment |publisher=Alliance for Automotive Innovation |date=July 2023 |url=https://www.autosinnovate.org/about/advocacy/right-to-repair/1%20-%20National%20Automotive%20Repair%20Data%20Sharing%20Commitment%20July%202023.pdf |access-date=2026-06-12}}</ref> | ||
<ref name="autocare">{{Cite web |author=Auto Care Association |title=Right to Repair Agreement a Thinly Veiled Attempt to Confuse Lawmakers and Drivers |publisher=Auto Care Association |date=2023-07-11 |url=https://www.autocare.org/news/latest-news/details/2023/07/11/right-to-repair-agreement-a-thinly-veiled-attempt-to-confuse-lawmakers-and-drivers |access-date=2026-06-12}}</ref> | <ref name="autocare">{{Cite web |author=Auto Care Association |title=Right to Repair Agreement a Thinly Veiled Attempt to Confuse Lawmakers and Drivers |publisher=Auto Care Association |date=2023-07-11 |url=https://www.autocare.org/news/latest-news/details/2023/07/11/right-to-repair-agreement-a-thinly-veiled-attempt-to-confuse-lawmakers-and-drivers |access-date=2026-06-12}}</ref> | ||
<ref name="mema">{{Cite web |author=Motor & Equipment Manufacturers Association |title=Get The Facts about Vehicle Right to Repair Agreements |publisher=MEMA |url=https://www.mema.org/get-facts-about-vehicle-right-repair-agreements |access-date=2026-06-12}}</ref> | <ref name="mema">{{Cite web |author=Motor & Equipment Manufacturers Association |title=Get The Facts about Vehicle Right to Repair Agreements |publisher=MEMA |url=https://www.mema.org/get-facts-about-vehicle-right-repair-agreements |access-date=2026-06-12}}</ref> | ||
<ref name="joint">{{Cite web |author=U.S. Department of Justice Antitrust Division and Federal Trade Commission |title=Joint Comment of the United States Department of Justice Antitrust Division and the Federal Trade Commission, Docket No. COLC-2023-004 |publisher=U.S. DOJ and FTC |date=2024-03-14 |url=https://www.ftc.gov/system/files/ftc_gov/pdf/ATR-FTC-JointComment.pdf |access-date=2026-06-12}}</ref> | <ref name="joint">{{Cite web |author=U.S. Department of Justice Antitrust Division and Federal Trade Commission |title=Joint Comment of the United States Department of Justice Antitrust Division and the Federal Trade Commission, Docket No. COLC-2023-004 |publisher=U.S. DOJ and FTC |date=2024-03-14 |url=https://www.ftc.gov/system/files/ftc_gov/pdf/ATR-FTC-JointComment.pdf |access-date=2026-06-12}}</ref> | ||
<ref name="nixing">{{Cite web |author=Federal Trade Commission |title=Nixing the Fix: An FTC Report to Congress on Repair Restrictions |publisher=Federal Trade Commission |date=2021 | <ref name="nixing">{{Cite web |author=Federal Trade Commission |title=Nixing the Fix: An FTC Report to Congress on Repair Restrictions |publisher=Federal Trade Commission |date=May 2021 |url=https://www.ftc.gov/system/files/documents/reports/nixing-fix-ftc-report-congress-repair-restrictions/nixing_the_fix_report_final_5521_630pm-508_002.pdf |access-date=2026-06-12}}</ref> | ||
<ref name="autocare-survey">{{Cite web |author=Auto Care Association |title=Survey: 84% of Independent Repair Shops View Vehicle Data Access as Top Issue for Their Business |publisher=Auto Care Association |date=2024-04-10 |url=https://www.autocare.org/news/latest-news/details/2024/04/10/survey-84-of-independent-repair-shops-view-vehicle-data-access-as-top-issue-for-their-business |access-date=2026-06-12}}</ref> | <ref name="autocare-survey">{{Cite web |author=Auto Care Association |title=Survey: 84% of Independent Repair Shops View Vehicle Data Access as Top Issue for Their Business |publisher=Auto Care Association |date=2024-04-10 |url=https://www.autocare.org/news/latest-news/details/2024/04/10/survey-84-of-independent-repair-shops-view-vehicle-data-access-as-top-issue-for-their-business |access-date=2026-06-12}}</ref> | ||
<ref name="nbc">{{Cite news |title=Automaker says it can't offer Mass. residents certain services over right-to-repair law |work=NBC10 Boston |date=2023-11-10 |url=https://www.nbcboston.com/investigations/consumer/automaker-says-it-cant-offer-mass-residents-certain-services-over-right-to-repair-law/3187555/ |access-date=2026-06-12}}</ref> | <ref name="nbc">{{Cite news |title=Automaker says it can't offer Mass. residents certain services over right-to-repair law |work=NBC10 Boston |date=2023-11-10 |url=https://www.nbcboston.com/investigations/consumer/automaker-says-it-cant-offer-mass-residents-certain-services-over-right-to-repair-law/3187555/ |access-date=2026-06-12}}</ref> | ||