Careers

Experiences

Industries

Offices

Our Firm

Pages

Our People

Updates

Practices

Home - Warner Norcross + Judd LLP

<div>Earlier this fall, George Hotz, a Silicon Valley inventor who some may call brash (wait till you watch the video), publicly announced the development and December 2016 public release of an aftermarket device, Comma One, that would render a handful of late model automobiles almost fully autonomous. According to Mr. Hotz, you simply have to remove the vehicle’s interior rearview mirror, replace it with a slick looking box that contains vision systems, connect the device to the car’s operating system and<em>—voilá—</em>you will be able to drive your car from Mountain View to San Francisco without requiring a driver to touch the wheel, the brake or the gas. All this for only $999! But, don’t take my word for it. Take 5-15 minutes out of your busy day and watch <a href="https://techcrunch.com/2016/09/13/comma-ai-will-ship-a-999-autonomous-driving-add-on-by-the-end-of-this-year/" target="_blank" rel="noopener">Mr. Hotz announce the device</a> at a September 2016 tech event.<br />
 <br />
When you’re done watching the video, hug your spouse, partner, child or pet, and be thankful the product release was pulled in October. The release cancellation is thanks to the watchful eye of the National Highway Traffic Safety Administration (NHTSA), who simply asked a few fairly simple questions like:</div>

<ol>
	<li>How does this work?</li>
	<li>How was it validated?; and</li>
	<li>How does this conversion comport with FMVSS 111?</li>
</ol>

<div>Hotz’s reaction to the rather innocuous letter was to immediately cancel the product’s release stating, “Would much rather spend my life building amazing tech than dealing with regulators and lawyers. It isn’t worth it.”<br />
 <br />
Well, personally speaking, I am very thankful for the intervention of lawyers and regulators in this instance as there appeared to be more than a few “minor” problems with this product. For one, the rearview mirror, which was to be removed, is mandated by FMVSS 111. Another “minor” problem is that this ready-to-go-to-market device was validated via only 300 thousand miles of testing. Last, but not least, Mr. Hotz admitted in his product announcement that the public would be Comma.ai’s beta testers! No! Thank! You!<br />
 <br />
This situation is further evidence of a culture clash between the traditional auto industry and high tech startups. We saw a similar situation with Tesla when they released “Autopilot,” which really isn’t autopilot. And yes, NHTSA followed up with Tesla via a similar letter asking some very simple straightforward questions.<br />
 <br />
This emerging technology is fantastic and almost ready for release but not until it is beta tested in controlled conditions and not until rules and regulations are proposed, debated and passed. We have a long way to go. And yes, lawyers will be and should be an integral part of the solution, while not being barriers to progress.</div>

core/freeform

Ahead of the Curve Auto Supplier

Automotive

Automotive TEST LAI

Autonomous, Connected and eMobility

Partner

Thomas J. “Tom” Manganello

West Coast Culture Collides with Automotive Reality

The Warner Norcross + Judd LLP lawyer responsible for the contents of our advertising and this website is managing partner <a href="/people/mark-j-wassink/" aria-label="Mark Wassink">Mark Wassink</a> who can be reached at <a href="mailto:mwassink@wnj.com" aria-label="email Mark Wassink">mwassink@wnj.com</a> or 616.752.2189. Please read our full <a href="/privacy-policy/" aria-label="see privacy policy">privacy policy</a> available on our website.

West Coast Culture Collides with Automotive Reality

professionals