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Comment by iMuzz | Hacker News Reader

Quick bit of feedback for any Comma employees lurking:

It took me a very long time to realize that this was a self-driving solution for existing vehicles. The hero just says

"Driven over 6 million miles" and then a "Buy Now".

When I scrolled down and looked at the product and read:

> We’ve added an infrared camera to provide 24/7 driver monitoring, an integrated panda, a custom cooling solution, and an OBD-C port with power supplied directly from the car.

I thought it was some kind of dash cam + driver sleep monitor? Also, most of those words don't mean anything to me.

Only after deeply investigating it did I realize that it's basically Tesla Autopilot for existing vehicles.

You have an awesome value prop though, "Bring autopilot features, to your car." Make that clear!

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I think this is deliberate. It's also why you have to download and install the self driving software separately. AFAIK regulators stepped in and killed comma as a self driving solution, so this is their way of still going forward and trying to maintain plausible deniability. It might not pass muster in a court of law, I don't know, but it should probably keep the regulators off their back.

It seems irresponsible for an engineering company to avoid regulators.

At risk of being snarky, I'm not sure 'engineering company' is the right moniker. They're an R&D shop making bleeding edge research available on a homebrew platform that can interface with recent vehicles to provide a level 2/3 driver assistance package.

The stuff required to pass the regulators is the long, slow, boring process of pushing reliability and failure modes into "safe" territory, while documenting the fact. This is the 'engineering' part. Making a system that works (probably, most of the time) isn't engineering, it's hacking.

"At risk of being snarky, I'm not sure 'engineering company' is the right moniker. They're an R&D shop ..."

... doing their R&D on public roadways, with unwitting / unwilling participants.

They are hackers. Geohot, the founder did iPhone and Play Station jailbreaking in the past. I wouldn't buy any safety critical equipment from them. They motto could be literally: go fast and break things.

Not necessarily.

Regulatory capture is a thing. Regulators, at least in part, exist to maintain a barrier to entry for any new players trying to enter a field dominated by large players.

Several major tech companies only exist because they broke rules in their early days. And most people agree the outcome was a net benefit to society.

As someone who drives on public roads (and has family and friends who drive on public roads) this is a frightening comparison and attitude.

Next time you drive, look around you at some of the other drivers. The ones with cell phones in their hands are more dangerous than someone with a comma.ai dev kit.

Fun story: I wanted to build a hypermilling coach/trainer system about 10 years ago and got to the point of having a poor mans ACC in a Scion. It didn’t brake though, only coasted to lose speed (thus requiring driver input). So I got the wild idea of tapping into the electronic brake distribution system to apply brake pressure when I needed to slow down. I figured out the system and was ready to tap into it when I had a dream that night. I was on the highway and all of a sudden two wheels decided to lock up from braking too hard. I stopped all testing on that car on public roadways after that.

My current car is hacked to provide lane centering when lane assist is on, but it’s still operating within the bounds of the factory electronic steering (so it can’t self drive/make 90 degree turns)

I agree, both cell phone drivers and people with unlicensed, untested, unregulated homebrew self-driving setups are dangers to everyone around them.

As are people with 15 year old rusted hoopties, drivers who had a fight with their significant other, disagreement with a colleague or whose sports team just lost, drivers who slept poorly the last few nights, drivers who are ill and taking cold medicine, cars with lamps out, worn tires, worn ball joints, bad shocks, no ABS, no vehicle stability control, etc.

I’m okay with enthusiasts repairing and modifying their cars and driving them on public roads, because I’d rather have that than a world where only certified cars, maintained at certified dealers, using only certified parts are permitted on the roads.

Maybe you're not a "car person". Apply the same principles to whatever field you have passion for. Only certified Intel parts may be added by Intel technicians to Intel computers, which must run only certified operating systems. Or only certified Edison lightbulbs may be added to certified Edison light fixtures by certified Edison technicians. Only certified firmware may be run on devices you're being allowed to rent from the certified manufacturer.

I agree, driving is dangerous. Why is the response to add another dangerous hazard? This argument is ridiculous.

Do you have evidence to support the hypothesis that cars equipped with aftermarket equipment are in general or with this specific system are more dangerous? Do you think such evidence should exist/be considered prior to banning a potential device?

The reason I ask is because there is a general topic of whether we should preemptively block new technology based on hypotheses, whether we should seek supporting evidence, or whether we should wait for confirming data before blocking freedoms to experiment. Said differently, do we ban everything until “proven” safe, allow everything until “proven” unsafe, or something in middle.

Experimentation using heavy equipment that has been modified with unlicensed and untested hardware and software designed to radically change its behaviour, in close proximity to people who haven’t consented to the experiment, should be illegal.

> but it’s still operating within the bounds of the factory electronic steering

That's Comma AI's approach. Their hardware spoofs the stock computer so it can send commands to the car's active safety systems. So there are some stock limitations, like the steering torque, that openpilot doesn't bypass.

This doesn't address the fundamental issue: a car is being controlled by an untested and unregulated system on public roads.

That's true, but how much oversight is really applied to the existing software systems on modern vehicles? Did national regulators review the design and coding on the electronic stability controls? I doubt it. Is the CAN bridge between the entertainment system and the critical systems bus (with ABS, ESC, power steering etc.) suitably hardened to protect against hackers (hint: no.) Who has reviewed the electrically assisted power steering?

Most things in a modern car are controlled by software that's far more opaque than OpenPilot. Don't get me wrong, a lot of their software and hardware architecture choices scare the heck out of me, but at least it's transparent.

That could be a way to describe all human drivers :P

I'm not sure what testing a regulator can do today that's more rigorous than the 10.5 million miles already driven by Open Pilot equipped cars.

It isn't being done by anyone the company is liable for

If Linux caused your house to burn down, who would be liable?

(Hint: I hope you have good insurance)

You're already driving on roads shared with garbage solution like tesla's '''autopilot''' this thing is no different other than the creators not being able to afford the regulatory bribe to deploy it.

It's a completely different product with a much wider number of configurations that end-users have to piece together from Wiki pages and packages they download themselves, loaded onto hardware they've installed in their cars with zero oversight from anyone qualified.

> end-users have to piece together from Wiki pages and packages they download themselves

Which makes it a ton safer than '''autopilot''' because by the time those users are done installing it they have a pretty clear understanding of its capabilities and limitations.

vs. the endless videos of morons driving tesla in '''autopilot''' mode with hands off the wheel because it's an incomprehensible black box of magical self-driving capability for them.

The regulator hasn't stopped tesla autopilot from causing accidents. It's just a competitive moat.

It doesn't take a 5 year ML PHD and millions of simulation miles to download and install packages.

And yet all of those resources have amounted to what all regulators agree is a SAE level 2 system, only qualified for hands-on lane-keeping assist, exactly like you'll find on a modern Mazda or any other number of cars without any of that hardware or ML PHDs.

Sort of proving the point that the resource pool of the incumbent doesn't necessarily translate to the value of the product.

Comma is bragging about 6 million miles drive. Tesla's Autopilot has over 2 billion miles driven. This has two cameras (EDIT: and apparently 1 radar that already exists in the vehicle). Tesla's has 12 cameras, 12 sonars, and 1 radar. This is backed by a company that apparently has received $8 million in funding. Autopilot is backed by a company with a market cap of $84 billion. You are welcome to your opinion of Tesla's product, but if that is garbage, I can't image the word you should use to describe this because the two products are in no way comparable.

You're listing specs which are a proxy for how much money the incumbent has, and saying that the regulatory barrier should be set at those specs for some reason.

None of those specs give any indication to the relative safety of the two systems though. And this is exactly what incumbents want. They want a small player to have to match their massive cash holdings to enter their market, even if the small player has a better product.

Here's some food for though: Tesla has been slapped with multiple lawsuits for misleading advertising of Autopilot. Regulators all agree that Autopilot is just an SAE level 2 system, same like those found on much cheaper cars with far less hardware and none of the marketing oversell.

I listed miles driven. That is a direct indicator of safety.

I also listed the number and type of inputs each system has. This might correlate with money, but it clearly also correlates with safety. One simple example, it is impossible for the Comma system to have 360 degree visual coverage of what is around you with just two cameras in the locations they are in.

Tesla does not use 12 cameras for autopilot. It just uses radar and 1 or 2 of the front facing cameras depending on the version. Not really different from OpenPIlot.

A selling point of HW3 is that it will use all of the cameras, so that's likely to eventually change.

You're making a lot of really wild assumptions about what correlates with safety without a shred of evidence to back it up.

Humans have two eyes, a pretty narrow field of view, no radar, no sonar. By your logic they're even worse, yet theyre so much better than Autopilot that it's unattainable for it to match.

>You're making a lot of really wild assumptions... without a shred of evidence to back it up.

>Humans have two eyes... yet theyre so much better than Autopilot that it's unattainable for it to match.

These two statements are pretty ironic back to back.

I'm not sure if we are ever going to convince each other of anything if we can't agree that there is a clear difference in track record when one product has been used for 2 billion miles and the other for 6 million.

I haven't seen any videos of OpenPilot vehicles swerving towards gore points or ploughing into stopped vehicles, though.

You are already sharing a road with people who are constantly distracted, drunk, or other. I would say the roads would be a much better place if there were more people who had a computer driving them.

Uber is not a tech company, it is a mini cab firm

Air BnB is not a tech company, it is in the holiday let's game.

On one hand yes, on the other the company wouldn't exist. Regulators are important, but they also serve incumbent interests as they raise the barrier to entry for newcomers. It's a way to pull the ladder up behind you once you've achieved success. I don't know how we can better balance those seemingly conflicting aspects.

> Regulators are important, but they also serve incumbent interests as they raise the barrier to entry for newcomers.

Call me crazy, but when it comes to products that could so easily cause death, a barrier to entry is a good thing.

Aaaaand that's why Americans need to pay 500 bucks for an insulin injector pen while Indians pay 10 bucks for the same device.

The problem with regulatory capture and arguing it's a good thing, is that there's a downside/cost to the barrier it creates. And often that downside outweighs the upside.

To be clear, no one is arguing regulation shouldn't exist. Just that the nature of regulation is to be captured by incumbents and serve a purpose orthogonal to protecting the people.

I didn't say regulatory capture is a good thing. I said that barriers to entry can be good in certain instances. In the instance of medical devices, the problem in the US has nothing to do with barriers to entry. If you can drive across the border to Canada and buy an identical product for a fraction of the price it would cost in the US, that isn't because the barrier to entry is too high in the US. The product already exists and is being produced, it just costs more due to a broken healthcare industry.

No, Americans are paying 500 bucks for a pen precisely because of regulatory capture. None of the manufacturers of the cheaper version have been successful in jumping the regulatory barrier to entry which the incumbents lobbied for, and tens of thousands of Americans suffer for it each year.

I have a hard time believing e.g. most european countries have less regulation in the medical sector than the US. Probably less corruption/"lobbying" (because corporate campaign distribitions are more strictly regulated in most other countries), but corruption quite different from regulation, even if both affect how law gets written.

Many times it’s hard to distinguish the difference between regulation and corruption. Sometimes they’re one disguised as the other. Not sure what method you have for distinguishing between the two, so please share!

I'd say they exist on different levels and shouldn't be conflated. Corruption is the undemocratic alternative to a democratic decision making process. Both affect regulation, e.g. law.

In what way is that scenario not suggestive of a barrier to entry to the US market for the maker of the product already being sold in Canada?

> Aaaaand that's why Americans need to pay 500 bucks for an insulin injector pen while Indians pay 10 bucks for the same device.

I can't speak for insulin injectors, but I know for a fact that the reason Indian pharmaceuticals are often times massively cheaper is because they ignore patents by which the majority of the world abides.

Now in many cases, the patent system is set up for incumbents who have enough legal muscle to develop and patent isomers, metabolites, or "extended release" versions of successful drugs which are losing their patent privileges. But that's not the whole story. We know that some patents and copyrights are needed to encourage investment in R&D.

India (used to?) just blindly copy drugs, ignore paying royalties, and take the profits. I haven't ever been on any blockbuster meds developed natively in India. Have you?

Taking another angle, when it comes to a product that could so easily save a net of 10s of thousands of Americans every year once fully developed, barriers to entry might be counter-productive.

(I’m actually fairly bearish on level 5 self-driving being “close”, but if it was, speeding that up would almost surely be worth throwing the switch on the trolley tracks for both the lives saved and the reduction in wasted attention of those who would have otherwise used a lot of their lifetime driving.)

I can never really understand this argument. Why can't we carefully craft regulations to scale in their burden with the company's ability to bear said burden in some way? Scale with revenue or head count numbers? Similar to how income at the lowest bracket isn't taxed, to lessen the burden on people much less able to pay.

Because (a) then you'd end up with things like pacemakers designed by sole operators because their regulatory burden would be that much lower than what a biomedical engineering firm would face, and (b) any such system would be trivial to game anyway.

We can, but usually it's the established encumbents who are helping draft the language of the legislation (which is better than politicians with no expertise working alone) and they are not incentived to encourage the kind of regulation you propose.

I like this idea a lot. We don't currently do this, but it would get most of the benefits without most of the downside. Seems like a win.

Count me in as well. I came here to make that comment.

I've had to scan the entire website and still cannot find a reference to a simple term like "self-driving" anywhere in the website. It seemed like a dashcam that warns the driver.

While the website doesn't directly state it, the entire purpose of the Comma hardware is to run the OpenPilot self-driving software (or "driver assistance" software, whatever you want to call it). Sure, you can run other software with it, but it works really well with the software that has already been written for it and is available on the same website.

The FAQ clears some of this up (https://comma.ai/faq), but I agree with the idea that it is purposefully obtuse to keep regulators off their back.

On the 3rd scrolling down "page" OpenPilot , there is a hard to see link "See OpenPilot in action".

When I watched the videos it made it clear what it does, i was lost before that.

If it doesn't say "self driving" anywhere, it might be presumptuous to say that's its intended purpose.

Seriously. The website does a pretty crappy job at explaining what the product actually is.

I think that's sort of by design. The NHTSA shut down their ability to sell in the US a few years ago. This seems to be some sort of stealth method to sell it again using the same sort of trick pharmaceutical companies use where they don't have to tell you any warnings if they don't actually tell you what the thing does.

https://techcrunch.com/2016/10/28/comma-ai-cancels-the-comma...

> Hotz tweeted from the official Comma.ai account that rather than providing the requisite response, the company would instead be cancelling Comma One entirely, and turning its attention to “other products and markets,” since Hotz says that the prospect of a life “dealing with regulators and lawyers… isn’t worth it.”

...Wow. Maybe don't develop autonomous driving tech then?

Their tech is within the top two right now, and Hotz has demonstrated a deep responsibility with it. Plus, it's all libre software.

Skipping regulators seems fine, given (unlike their competitors) they're acting responsibly. Their eye-tracking tech is really cool, too, and prevents the Tesla problem of drivers losing focus.

>Their tech is within the top two right now,

how can anyone make that statement in the same breath as declaring that dodging regulators is fine? Who the hell evaluates the quality of the product if not regulators?

Are we supposed to take George Hotz's or the companies word for it?

I am a comma user, engineer and autonomous vehicle enthusiast. Comma truly is second only Tesla if we leave out Waymo, but Waymo is only operating in Geofenced areas.

I have used every single pilot assist out and they're all quiet frankly terrible in comparison. I will give GM Supercruise a nod in how well it's done but again, it's Geofenced.

You can use it; you don't have to take Hotz's word, or the company's word for it. How everything works is completely open, and it works pretty well. Also, see:

https://news.ycombinator.com/item?id=21987585

I thought the computer vision model wasn't open?

The quality of a product is pretty much always determined by the marketplace, not regulators.

I feel like the Boeing 737 MAX situation is a clear demonstration that this isn’t really the case, especially in the realm of safety regulations.

It seems to me like the market has developed a better idea of the product quality there than the regulators initially did.

It's open sourced. Everyone is able to evaluate quality.

The people who are consumers of these products are not necessarily software engineers, so no everyone cannot evaluate the quality of these products. Secondly, the models are not open source, and even if they were looking at them tells them nothing about the quality of the product.

The only way to actually access the quality of these products is through independent testing by a body that is qualified and reputable enough to do so. Which in my opinion should happen before even a single one of these devices is actually allowed to participate in regular traffic.

It was made fully opened sourced last year.

https://medium.com/@chengyao.shen/decoding-comma-ai-openpilo...

> it was made fully opened source

Unless something changed I missed, the part I emphasized is not true. There’s binary blobs in the source code that last I heard would not be released.

Do you have any evidence to support your claim that Hotz has done anything resembling "deep responsibility"?

Because from the scraps that I've managed to put together, he seems childish and irresponsible.

https://www.youtube.com/watch?v=iwcYp-XT7UI

This Lex Friedman interview is pretty explanatory on the topic of responsibility.

A couple of highlights, which point to Comma being at minimum more responsible than Tesla: Comma doesn't advertise itself as anything beyond L2, unlike Tesla; Comma doesn't fuck up eye-detection, it refuses to cooperate with a driver who has their eyes off the road.

Their tech is nowhere close to the top two.

Or maybe don't have such a stringent regulation ?

As I understand it, "the NHTSA shut down" is a serious approximation of the story. They marketed aftermarket self-driving kits while not getting any regulatory approval, and when the NHTSA sent them a letter saying "So, uh, what's this thing you're selling? Can we meet?" they immediately chose to shut themselves down instead of meeting.

It isn't an actual consumer product, it is a development kit.

it's a dashcam with a passive driver assist system, the openpilot stuff is a separate product meant to be installed onto the "comma two" by the user

Yes. The heck is an "integrated panda"?

OBD-II Interface Dongle

https://github.com/commaai/panda

https://comma.ai/shop/products/panda-obd-ii-dongle

Maybe the target customer is the King of All Cosmos.

I only knew from your comment what is this after I came back from the site spent minutes trying to find out. For a couple of seconds I only saw the "Buy now" button and I though "Buy what the fuck?" Really annoying design.

Came here to say something similar. I briefly thought it might have been a self-driving add-on because of this bit:

>The comma two does not ship preloaded with software capable of controlling your car. Open source software can be installed separately.

But then I figured that if it actually did that, they'd be screaming about it, not talking about how you can watch your drives.

Kind of hilarious.

Came here to make this comment! Seems like a cool product - but most visitors to the webpage will never learn what the product does, since it is buried in the page.

It's vagueish on purpose. They only want smart people using. It's still a dev kit. Not consumer product yet.

From comma's discord:

"if people can’t figure out what it is, it isn’t for them"

It's also definitely not for everyone who figures out what it is. They should be up front about what it does and the legality around using a device in that capacity.

I still feel like they've taken it a level too far. I already knew comma.ai from past news, and even with that context I wasn't sure if they pivoted to fancy dashcams.

I literally thought I was looking at some funky games console first....but which you mount on your dashboard for some reason? And even after reading the entire website I didn't get that it was meant to be for autopilot - I only got that after reading your comment.

I completely agree, I never heard about it before, after looking a few minutes at the websites and some youtube videos I realized it was a self-driving thing you can install on stock vehicles that support it.

Better information / overview.

Look very promising tho!

Same! I had no idea what this was even after reading most of the website.

Yea I had to come to the comments to figure it out.

This. I clicked from the HN-linked page over to the main page, scrolled through it, and still had no idea what I was looking at.

Came here to say the same thing! Very difficult to understand what this actually is.

I read the whole website and still not much idea what this is.

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