Comma don't even say _how_ the model works! What layers are there? What learning strategies are they using? What do they do? It's literally a black box! "All you have to do is see how it behaves for different inputs" is just black box reverse engineering! Machine Learning is NOT a magic black box.

Comma have constructed a "stack" of models, just as you would connect a series of functions to make a kernel in the mathematics sense, or a series of algorithms or instructions to make a program. And that stack is entirely closed.

https://medium.com/@chengyao.shen/decoding-comma-ai-openpilo... here is an example of reverse-engineering the driving model. If Comma released this exact sort of documentation, including what ML modeling strategies they were using, what each input and output parameter affected, and how the model was trained, I could maybe consider the system open.