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Culture War Roundup for the week of May 6, 2024

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The "S" in IoT stands for Secure

Boy, looong ago now, I broached the topic of security standards for techno-mabobs. At that time, I mentioned that the UK was considering some legislative proposals on the matter. I can't find the comment where I described what I viewed as the core driver of the tension over the topic - the culture of tech folks. That is, they are so used to the 90s consensus that software is gee wiz magic that is pure and sanctified, is the solution to world peace and all of life's problems, and can never possibly be the cause of anything bad, ever. The 90s conclusion was that government absolutely can. not. touch it. Hands off. No regulation whatsoever. No liability whatsoever. No matter what happens, they must have an absolute immunity stronger than even the strongest version that Donald Trump could have ever dreamed of claiming.

Justifications for this view have shifted, but I've always felt they've had a flavor of, "We can't be regulated! We're autistsartists! We make unique snowflake masterpieces! We have to move fast and break stuff! If we're ever held accountable for breaking anything, even for the most egregious of practices, then the entire economy will grind to a halt!" Whelp, after years of incident after incident exploiting the IoT-of-Least-Resistance, including things like ransomware takedowns of major corporate networks and huge botnets of smart refrigerators, we're about to see how true that really is.

Hitting the wire last week, the UK has dropped regulation for smart devices that are sold there. In my original comments five years ago, they were proposing three items; I had only asked for one (the most incredibly basic one - don't have every bloody device have the same default password). I really feel like it's a case of, "If you resist and throw enough of a shitfit over the really simple stuff, it's going to come back around in a much stronger way that you really won't like." The full document of "Baseline Requirements" speaks to fourteen items:

● No universal default passwords

● Implement a means to manage reports of vulnerabilities

● Keep software updated

● Securely store sensitive security parameters

● Communicate securely

● Minimize exposed attack surfaces

● Ensure software integrity

● Ensure that personal data is secure

● Make systems resilient to outages

● Examine system telemetry data

● Make it easy for users to delete user data

● Make installation and maintenance of devices easy

● Validate input data

● Data protection provisions for consumer IoT

Each area is broken down into one or more specifics. There's a helpful table on page 32, detailing whether the requirement is Mandatory, Recommended, and/or Conditional. This is important to know, because a bunch of them are truly just recommendations, but even many of the ones that are Capital M Mandatory are also Conditional, which is actually displaying quite a sense of care about the diversity of devices and possible situations. For example, they acknowledge things like "constrained devices", which is a "device which has physical limitations in either the ability to process data, the ability to communicate data, the ability to store data or the ability to interact with the user, due to restrictions that arise from its intended use". Here, they give some explicit examples, like "The device cannot have its software updated due to storage limitations, resulting in hardware replacement or network isolation being the only options to manage a security vulnerability."

I think this truly is a culture war between the culture of technokings and the culture of They Can't Keep Getting Away With This, and no culture war offensive ever comes without a counteroffensive. Will major corporations, either American or Chinese, bow the knee? Will they pull out of the UK in a weird, polar opposite anti-security stance to the position that has led other companies to pull products like Signal/Telegram from countries that threatened to make them less secure? The UK may be the sixth largest economy in the world by GDP, but that's still only about 4%. Will they go full tizzy and make separate products, where the secure versions go to the UK and the less secure versions go elsewhere? If they don't pull out and don't make different versions, than everyone in the world just got a huge security upgrayyyed. If they don't pull out and make different versions, other countries have a green light to mandate that they should also get the good stuff. So, if they're even thinking about pulling out, they've gotta rally the troops, punish any defectors, and really make the UK feel blockaded as a warning shot to the rest of the world.

My guess is that they'll bow the knee and just do this stuff for everyone. It's pretty much all stuff that everyone has known that they should be doing for quite a while now. Will it cost a little extra? Sure. Will they have to deal with some annoyed developers who feel constrained by law, as basically every other industry ever does, and eventually have to bring their culture into the Industrial Age? Sure. I doubt that having to pay $9 for a smart plug instead of $6 is going to change much about the economics of wiz bang gizmos... but it just might be a step toward not having newspapers filled with nightmare exploits causing millions in damage... at least not every week.

The cost of compliance -- which is to say, the reams of paperwork and signoffs necessary -- will make this impractical for startups. The large companies making this stuff will do it -- eventually, with the UK getting delayed releases. The Chinese knockoffs will continue to be sold unlawfully, and a lot of new stuff just won't appear in the UK at all.

Justifications for this view have shifted, but I've always felt they've had a flavor of, "We can't be regulated! We're autistsartists! We make unique snowflake masterpieces! We have to move fast and break stuff! If we're ever held accountable for breaking anything, even for the most egregious of practices, then the entire economy will grind to a halt!"

Sneer all you want (I guess you're a Real Engineer), but I think a big reason bits have continued to grow while everything else has stagnated is the regulators haven't caught up with the bits yet.

the reams of paperwork and signoffs necessary

My read is that they literally just need to fill in that table that I mentioned on page 32. That's not a lot of reams.

I guess you're a Real Engineer

I am most decidedly not a Real Engineer.

I think a big reason bits have continued to grow while everything else has stagnated is the regulators haven't caught up with the bits yet

Like I mentioned, we will see if the economy of bits will grind to a halt... or if they'll take the couple days necessary to not have a default password and to write "Yes, we don't have a default password" in the table on page 32. Perhaps you could formulate your prediction in numerical terms? Maybe something about growth rates in the tech sector over the next ten years? Maybe something about stock prices and how they'll reflect this immense stagnation? Or maybe an explanation for why the market hasn't already priced this in and had a massive drop in valuations in the past week in response to oppressive new regulation?

if they'll take the couple days necessary to not have a default password and to write "Yes, we don't have a default password" in the table on page 32

I don't think you understand how this works if you think that this is the only necessary step once this becomes an obligation by law.

Since this is a potential liability, someone will have to be responsible for filling that form, and they'll also have to have sufficient means to enforce that the form is true. That person is most likely a lawyer and not technical themselves, which means they'll have to rely on auditors, which means not only that you'll have to pay money to get those audits done, you'll also have to find a company that will do them on the tech stack that you are running and is familiar with the intricacies of the particular legislation you're trying to abide by.

And once the bureaucratic machine gets started like this it doesn't stop, standards will get more complex, there will be people whose whole job is to ensure that they are followed and the costs will balloon accordingly.

Compliance is a huge industry. If following the law was that simple, it would not be.

maybe an explanation for why the market hasn't already priced this in and had a massive drop in valuations in the past week in response to oppressive new regulation

Like Bastiat says, there is what is seen and what isn't seen.

What is seen is the valuation of established companies that have compliance departments and who'll be able to integrate regulation with a marginal cost change they can pass on to the consumer. What isn't seen is how much harder it is or will be to get funding for a startup that designs novel appliances because the costs to enter the market are now higher.

Compliance is a huge industry.

Weird. I hear about that from my friends in literally every other industry ever. They still seem capable of operating.

What isn't seen is how much harder it is or will be to get funding for a startup that designs novel appliances because the costs to enter the market are now higher.

I'm always sympathetic to concerns of regulatory capture putting barriers to entry in front of small businesses. Totally agree that this is the single strongest argument against these types of requirements. I just doubt that these particular requirements are that onerous. Plenty of smaller shops that actually care about not being a security clusterfuck already do these kinds of things, and you can do most of them without too much difficulty as a hobbyist. In any event, if you're a start up that can't figure out how to not have a default password on all your devices, I actually kind of don't want you selling stuff, anyway.

They still seem capable of operating.

Where is the innovation in any other industry over the past decades exactly? You know, since they brought these in.

How expensive is it to build a bridge now, versus a hundred years ago, adjusted for inflation? "capable of operating", what a joke.

As Kulak is fond of saying, the reason we don't have flying cars isn't that they haven't been invented, it's that they've been made illegal. They were commonly flown (and shot down) by teenagers in the 1910s.

if you're a start up that can't figure out how to not have a default password on all your devices, I actually kind of don't want you selling stuff, anyway

This is the tired same equivocation that motivates all such regulatory barriers. I complain about having to fill forms, you retort about the justifications for the form existing as if I didn't also have such a concern.

There are other answers to the problems of humanity than increasing the size of the bureaucracy. Just no other that fits into managerialism.

Where is the innovation in any other industry over the past decades exactly?

You know, since they brought these in.

Let's go with a simple one - the shale fracking revolution in the oil/gas industry. But nobody is actually going to go counting these things, because no one really has any sort of consistent argument for which sorts of regulations stifle innovation. Again, I totally realize that they do sometimes, in some ways. But what sort of massive innovation is going to be stifled by requiring devices to not have default passwords? Like, surely we can agree on that one. We could at least leave open arguments for other requirements, and I would welcome a wide-ranging debate on them. But if we're stuck with just theoretical arguments, totally disconnected from any specifics, in a way that can't capture basic truths like, "Being forced to not have default passwords is not a significant barrier to innovation," then we're not going to get anywhere.

I complain about having to fill forms, you retort about the justifications for the form existing as if I didn't also have such a concern.

Ok, so you also have a concern about default passwords. What are you going to do about your concern?

Since we are talking about the UK, shale fracking is illegal there. Hardly a revolution.

Irrelevant. Obviously, people can choose to regulate something specific away. The question is whether there has been "any" innovation in "any" other industry (that is, the non-bits ones that have more regulation). Unless you're claiming that the US has no regulation on the oil/gas industry, the shale revolution, which literally has changed the world at a geopolitical scale, is a huge counterexample.

But there are many others. Space X. Ozempic. Etc. It's really hilarious to have all the huge techno-optimists, who think that AI and tech more broadly is going to revolutionize literally everything, and at the same time, they imagine that the tiniest amount of regulation on fucking light bulbs will grind literally everything to a halt.

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