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 *Disparagement of non-OEM parts and independent repair; A.Physical Restrictions Physical restrictions, which can take a variety of forms, are restrictions that limit the ability to open devices or physically remove and replace component parts. These restrictions were raised at the Workshop and in multiple comments as a common practice that limits consumers’ ability to repair products or devices they own.
 * Software locks, Digital Rights Management and Technical Protection Measures; and
 * End User License Agreements.

Repair advocates have identified different ways that manufactures build physical restrictions into their products. Such restrictions include highly specialized nuts and bolts that require unique screw heads to open a device or machine.

Another physical restriction that was discussed in the record was the use of glue to close device cases or chassis or to secure component parts within a device. Repair advocates also raised concerns about the increased use of soldering on motherboards and other technical components. By soldering RAM, storage or other components to a motherboard, manufacturers eliminate the ability of consumers to replace or upgrade individual components of a product.

Finally, commentators highlighted the trend by manufacturers to weld or close the exterior of products. Eliminating the ability to open a device eliminates the ability to repair a product. B.Unavailability of Parts, Manuals, and Diagnostic Software/Tools Repairs may be made more difficult or impossible to perform by individuals or independent repairs shops due to their inability to access parts, manuals, and diagnostic software and tools. This section discusses each type of restriction in turn.
 * 1.

Some manufacturers make parts available only to their authorized repair networks. For example, LKQ Corporation (“LKQ Corp.”) stated that in the automobile industry, where replacement parts have been generally available outside of manufacturers’ repair networks, several manufacturers, such as Volvo, limit the availability of key replacement parts to only their authorized repair networks.