Encrypted Bootloaders, The Law and Your Rights
TheDiabolicaL1
Contributor - Level 1

The Law:

§ 27.16 Network access requirements for Block C in the 746–757 and 776–787 MHz bands.


(a) Applicability. This section shall apply only to the authorizations for Block C in the 746–757 and 776–787 MHz bands assigned and only if the results of the first auction in which licenses for such authorizations are offered satisfied the applicable reserve price.
(b) Use of devices and applications. Licensees offering service on spectrum subject to this section shall not deny, limit, or restrict the ability of their customers to use the devices and applications of their choice on the licensee’s C Block network, except:
(1) Insofar as such use would not be compliant with published technical standards reasonably necessary for the management or protection of the licensee’s network, or
(2) As required to comply with statute or applicable government regulation.
(c) Technical standards. For purposes of paragraph (b)(1) of this section:
(1) Standards shall include technical requirements reasonably necessary for third parties to access a licensee’s network via devices or applications without causing objectionable interference to other spectrum users or jeopardizing network security. The potential for excessive bandwidth demand alone shall not constitute grounds for denying, limiting or restricting access to the network.
(2) To the extent a licensee relies on standards established by an independent standards-setting body which is open to participation by representatives of service providers, equipment VerDate Mar<15>2010 16:46 Dec 15, 2010 Jkt 220201 PO 00000 Frm 00334 Fmt 8010 Sfmt 8010 Q:\47\47V2 ofr150 PsN: PC150325 Federal Communications Commission § 27.20 manufacturers, application developers, consumer organizations, and other interested parties, the standards will carry a presumption of reasonableness.
(3) A licensee shall publish its technical standards, which shall be nonproprietary, no later than the time at which it makes such standards available to any preferred vendors, so that the standards are readily available to customers, equipment manufacturers, application developers, and other parties interested in using or developing products for use on a licensee’s networks.
(d) Access requests.
(1) Licensees shall establish and publish clear and reasonable procedures for parties to seek approval to use devices or applications on the licensees’ networks. A licensee must also provide to potential customers notice of the customers’ rights to request the attachment of a device or application to the licensee’s network, and notice of the licensee’s process for customers to make such requests, including the relevant network criteria.
(2) If a licensee determines that a request for access would violate its technical standards or regulatory     requirements, the licensee shall expeditiously provide a written response to the requester specifying the basis for denying access and providing an opportunity for the requester to modify its request to satisfy the licensee’s concerns.
(e) Handset locking prohibited. No licensee may disable features on handsets it provides to customers, to the extent such features are compliant with the licensee’s standards pursuant to paragraph (b) of this section, nor configure handsets it provides to prohibit use of such handsets on other providers’ networks.
(f) Burden of proof. Once a complainant sets forth a prima facie case that the C Block licensee has refused to attach a device or application in violation of the requirements adopted in this section, the licensee shall have the burden of proof to demonstrate that it has adopted reasonable network standards and reasonably applied those standards in the complainant’s case. Where the licensee bases its network restrictions on industry-wide consensus standards, such     restrictions would be presumed reasonable.

Specifically:

(e) Handset locking prohibited. No licensee may disable features on handsets it provides to customers, to the extent such features are compliant with the licensee’s standards pursuant to paragraph (b) of this section, nor configure handsets it provides to prohibit use of such handsets on other providers’ networks.

The encryption used on 4g devices that verifies whether the phone is using "Official Verizon Software" prevents an end users ability for use on other providers' networks.  By way of the encrypted bootloader, the device is effectively made worthless because when a new carrier flashes their software to the phone, the bootloader recognizes it as "Unapproved Software" and puts the device into a boot loop.

You have the right to request these keys, software or programs to unlock your device from Verizon.  If you ask, and are denied your request from a Verizon Representative, you can take your complaint to the FCC where

     "(f) Burden of proof. Once a complainant sets forth a prima facie case that the C Block licensee has refused to attach a device or application in violation of the requirements adopted in this section, the licensee shall have the burden of proof to demonstrate that it has adopted reasonable network standards and reasonably applied those standards in the complainant’s case. Where the licensee bases its network restrictions on industry-wide consensus standards, such restrictions would be presumed reasonable."

comes in and Verizon will be forced to prove their lock on your device and their prevention of allowing you the option to take your device to another carrier is "reasonable."

This is for 4g devices only.

Thanks

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Re: Encrypted Bootloaders, The Law and Your Rights
Tidbits
Legend

Locked bootloader isn't classed as a Block C rule violations.  If it was it WOULD have been a problem since the Thunderbolt.  What the unlocked means...  The sim card slot, and NOTHING more.  The CDMA portion isn't tied to the block C rules at all.

When Verizon moved over to VoLTE then the device will always be unlocked as it will only have an LTE radio.  Until then nothing has and will change.

Know your devices and know your rights.

Reason why the locked bootloader isn't part of a feature block is because it is a security feature which is allowed, and it has nothing to do with the overall function of the device.

Re: Encrypted Bootloaders, The Law and Your Rights
TheDiabolicaL1
Contributor - Level 1

I appreciate your reply, thanks.

However, in this case, you are mistaken.  I own a device that falls under block "C" requirements.  My Samsung S3. I am interested in taking my device to another network. However, they must be able to flash their software on my device.  Because of the system check installed by Verizon (at the boot loader,) the flashing of the new software, by my new carrier "bricks" the device which means my ability to take the device to a different carrier is eliminated.

Verizon needs to remove the software on my device which checks for "Verizon Approved" software if I decide to take my device to a different carrier.  US Cellular, or whoever cannot implement their own software/security on my device, at my request which is, in fact, a clear violation.

To reiterate, I am not asking the bootloader to be unlocked "just because."  It is strictly to switch carriers.

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Re: Encrypted Bootloaders, The Law and Your Rights
Ann154
Community Leader
Community Leader

And why did you purchase a Verizon Wireless phone if you were just going to use it on another carrier? Buy a phone that works for that carrier.

I'm most definitely NOT a VZW employee. If a post answered your question, please mark it as the answer.

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Re: Encrypted Bootloaders, The Law and Your Rights
TheDiabolicaL1
Contributor - Level 1

Simply, Verizons actions after the point of sale.

I currently have a defective device.  I am being told that if I swap out my S3 for another S3 that it uses what's left of my 14 day guarantee and eliminates my option to step into a different phone if my second S3 fails to work correctly as well unless I purchase it for full retail, or purchase it used.

Apparently, there is no delineation between Warranty Replacement and simply not liking the device. 

Personally, I think it's poor business practice.

More to the point, I fail to see why it makes a difference that I would want to switch this phone out to a different carrier.  The reasons are irrelevant. The fact is, I cannot take my device to a different carrier because of Verizons software check that takes place when the phone is booted up.

It's well known flashing any other carriers official software "bricks" the phone.  This prohibits my ability to use said phone on any other carrier which is written into the law as explicitly prohibited.

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Re: Encrypted Bootloaders, The Law and Your Rights
Tidbits
Legend

Like I told you. It does NOT fall under block c rules. The S3 has a CDMA radio which DOES NOT follow block C rules. If there was a carrier that supported LTE(700mhz) the sim portion would work.

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Re: Encrypted Bootloaders, The Law and Your Rights
Tidbits
Legend

Return the device within the 14 days and buy the developers version. Problem solved.

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Re: Encrypted Bootloaders, The Law and Your Rights
TheDiabolicaL1
Contributor - Level 1

No carrier will accept a device running a different carriers Operating system and proprietary software.  In order to flash any software to the device for a different carrier, the software implemented by Verizon  that verifies it is "Approved by Verizon" must first be removed.  No radio can be flashed unless approved by Verizon.  No Kernel can be flashed unless approved by Verizon.  Specific apps cannot be removed unless approved by Verizon.  Doing any of the fore mentioned requirements to take the device to another carrier bricks the device.

I was told by Verizon if I wanted to take the device to a different carrier, I simply needed said carrier to flash their software to my device.  That cannot happen without changing the kernel.  If you change the kernel on the Samsung Galaxy S3 or any other device with an encrypted bootloader, to something not "approved by Verizon" the device ceases to operate and one is stuck with a "please flash Verizon Approved Software" (or some such thing) as the ONLY way to restore functionality.

Once the device has been removed from Verizons network and is no longer under any obligation to Verizon, how would one flash another carriers software to the device, if the device still checks for "Verizon approved software" with no possibility to turn it off?


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Re: Encrypted Bootloaders, The Law and Your Rights
TheDiabolicaL1
Contributor - Level 1

I've talked to Samsung and they are unaware of this "developers edition" and when said device will be released.  Furthermore, the rep I spoke with said it was possible the "developers edition" was propaganda by Verizon to get purchasers of the SGS3 passed the 14 day mark. *edit*  I should make it clear this was his opinion, not an official statement from Samsung.

I'm glad you brought that up though.  Seeings as how VZW states it's for the "security of the network" that phones be locked, why then, would they offer, for use on their network, an unlocked version of the exact same phone they've locked down and are currently selling?  Sounds highly suspect to me.  Sounds like complete B.S. to me.

Until the "Developers Edition" is being sold, it's release is speculative at best.  Again, this doesn't address the root problem with ones lawful ability to use the device on another network as stated by the law I pasted above.

The D.E. may provide an easier solution to put said phone on another network as one could easily flash the required software without rendering the device bricked, however, no where in the law does it say that if one desires to change networks, the purchaser should have bought a Developers Edition phone that didn't come with Proprietary Verizon Software which renders the device useless if you try to flash a different OS.

But maybe I missed it... ?

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Re: Encrypted Bootloaders, The Law and Your Rights
TheDiabolicaL1
Contributor - Level 1

Lets try it like this...

Is the Samsung Galaxy S3 capable of running on the Block "C" frequencies?  Yes

Was the reserve price met to implement the open standards of 27.16?  Yes

Is the Samsung Galaxy S3 required to follow the guidelines set forth by 27.16?  Yes

Is Verizon allowed to lock my device to Verizon software?  No

Was Verizon supposed to allow my phone the ability to be used on any carrier of my choosing?  Yes

Did they do that?  No

How do they prevent my option to use my device on any carrier of my choosing?  By locking the bootloader which  explicitly prohibits the flashing of any software not approved by Verizon for the use of the other carrier.

Am I allowed to exercise my right to take my device to the network of my choosing?  No

What specific part of the code does this violate?  Section (e)

Which states?  (e) Handset locking prohibited. No licensee may disable features on handsets it provides to customers, to the extent such features are compliant with the licensee’s standards pursuant to paragraph (b) of this section, nor configure handsets it provides to prohibit use of such handsets on other providers’ networks.

"configure handsets it provides to prohibit use of such handsets on other providers' networks."

One last time.  Does the encryption on the bootloader restrict your ability to use your device on a different carrier?  YES!

Is it clear enough for you?