The soul of a new machine

The FB2900 is close...

When launching a new product, especially when we are talking a real, electronic, product, there is a lot to do.

There are some time consuming and hard parts in designing schematic, PCBs, metalwork/case, software. There are loads of fiddly bits in terms of cosmetic decisions on colour and layout of the artwork on the front/back panels, and all sorts of things like that.

Then, when you have all of that, there are a few rather annoying things, one of which is the new safety standards we have to follow: BS EN 62368-1:2014.

This is new. Last time we did a product it was way simpler. We still have to do all of the EMC testing, which is pretty straightforward and was done some time ago, but the new safety testing is much more work.

This is, of course, all good stuff. We are good on safety. We have a good solid metal box which won't catch fire! We have a proper physically isolated double insulated power supply. In fact we redesigned the whole power supply from the last model and it allows some addition DC options we will have shortly (at this rate, at the same time as mains versions).

But the last step of safety testing needs a final production sample. Sensible. Sadly that means little details that are usually minor things at the end of the production like the printed fascias, and the quick start guide, are actually necessary for the safety testing! The manual includes mandatory details of power, and humidity, and temperature, and altitude, and so on. Having the manual as supplied ready, and all of the bits to make a final production sample, is needed, and then we have to wait weeks for the final sign off, probably. These people are in no rush, it seems.

So I really thought we would be shipping by now - we have hundreds on the shelf ready to go and customers eagerly awaiting the new product, and we have a fly in the ointment. The damn printers for the fascias. Promises of quick turnaround digital prints ahead of the final screen prints so we have our production sample were clearly outright lies (48 hour turnaround says the salesman). Over a week later we get one side and not the other.

I was really pissed off at that (somewhat shouting at one of my staff even, not his fault). I was literally sat here waiting for news on this - have they finally arrived after promise after promise, and then find they sent only one side and not the other. This one minor supplier has added a week or more to when we can start selling these. I am exasperated.

But, calm down, step back, and let my staff do their stuff. We wait and see when the other side arrives and we can finally send the production sample for final safety testing. It will happen in the next few days. There is no guarantee we pass, but we know we are doing well, and we know the issues and we are good. We are pretty sure of that. I could find there is some other delay in a week to two's time, but we know there can be nothing major.

Once we finally get the sign off, we can do the formal paperwork, declaration of conformance and attach the dreaded "CE" mark to the product and start shipping.

In the mean time, next week or two, we may have a few prototypes for evaluation for some select customers. If you get one, you can consider yourself special.

But what makes the FB2900 special?

FireBricks are a tad special. There are many routers and firewalls and all sorts around now - when we started there were not. But there are actually only a handful of underlying operating systems out there - linux, vxworks, maybe a couple of others. We have our own operating system from scratch and it is all UK designed and built. We control every line of code from scratch and ensure no back doors.

The FB2900 is the latest in the long line of FireBrick products. It builds on the FB2700 but is a lot faster (up to around 750M routed traffic rather than 350M) and has an extra port (a 5th port is SFP).

This makes it truly ready for the latest Internet links, 330M G.fast and FTTP, and multiple bonded FTTC.

The SFP allows true fibre lines, and even some of the new DSL SFP modules to be used directly.

The DC options are interesting - I mean, who wants to use a FireBrick in a car or a truck? Well, you would be surprised, but what of alarm panels? Many alarm panels have 12V DC lead acid backup and these days they need Internet. A 12V FB2900 with SFP DSL could be that backup for a long time. The power requirements are really low. This is actually what I plan personally at home, albeit with fibre SFP.

It also has a few gems that are waiting in the wings. We have a true random number generator that will come in to its own as we launch newer software in the coming months. It even has a hardware AES crypto processor which we really hope to link in to the IPsec code later in the year. The key here is the software updates are free and automatic, so these advances will be in there as soon as we launch them. Obviously we need to do a lot of work on these, so no guarantees yet, but the hardware is built to support them.

Oh, and unlike previous models we actually have a rack/wall mount kit. It does one or two FB2900s in 19" 1U or a wall mount, either way round/up.

Number right?

There are many legal systems to create and protect certain rights, such as copyright, design right, database rights, patents, and so on.

However, unless I have missed something, there seems to be one obvious right that is missing. I am not suggested we make a law for this, but I am interested that this seems to be an obvious possible issue that does not have the same legal protection.

There are a lot of situations where some unique allocation of number or name space exists within an application that therefore needs some management and allocation. Some simple examples are :-

• Credit/debit card numbers
• Bank sort codes
• Telephone numbers
• MAC addresses
• Product codes (for UPC/EAN barcodes)
• IP addresses
• AS numbers
• Domain names

Now, in some cases, these are only usable within a specific group of people that all agree to follow a common authority. So, for example, ISPs all agree to work together and interconnect. Now, in theory, there is nothing to stop an ISP picking IP addresses at random without using the internationally agreed hierarchy for managing IP address allocations. However, other ISPs will simply not peer with them, or will not route those IP addresses to/for them. So it won't work. There is no need for a law to control who is allocated the numbers.

Indeed, I think, in most cases (a lot of the above examples) there is basically a club you have to join to be able to do anything, and the other members only play if you follow the club rules.

Even so, in some cases, there are laws for some specific things, like telephone numbers. It is defined by law how communications providers use numbers as part of the national numbering plan and that OFCOM manage the number allocations. But this is a specific law for that specific case.

There are some interesting edge cases though.

Barcodes is one. We have dealt with GS1. FireBrick paid for a small block of UK EAN product codes so we have barcodes for the sleeves of the FireBricks and for Ignis (the dragon). This is in the off chance that we managed to sell to some retail outlet like PC world. However, given that GS1 charge annually and nobody was actually using the barcodes, we decided not to renew. GS1, of course, said we could no longer use the numbers and had to ensure barcodes were not used with those numbers any more.

This led to an interesting discussion. Apparently they even have an "enforcement" team that look for unregistered numbers in-use. The question then is what do they do? They got quite stroppy when I asked questions, like why not? Well step 1 was easy, because FireBrick had a contract, so I said that was fine, A&A were using the numbers instead and A&A had no contract. They did not like that and pointed out that they retain all rights in the numbers allocated.

This is where it got interesting as I asked exactly what rights they were retaining. They had no answer. I pointed out copyright does not apply, neither do design rights, database rights, patents. There appears to be no generic legal mechanism for establishing a right to management of allocations within a namespace such as UPC/EAN product codes. So actually, from what I can see, nothing to stop A&A using the numbers that were allocated to FireBrick without paying GS1. What this meant is the existing printed sleeves and existing labels on Ignis dragons did not have to be scrapped.

Now, in practice if some retail outlet want to sell FireBricks we'll subscribe again I am sure. A retail outlet may well require as part of the contract with them the use of valid/current EAN product codes. So we are back to the enforcement by joining the club, which is fair enough. Though I did wonder if retailers really care as long as unique within their inventory. I did tell GS1 that as they know we have products (Ignis mostly) with these barcodes it would be negligent / irresponsible if they knowingly re-allocated the codes to someone else.

Of course, another thing may be that retailers only need a code that is valid and current which means one could perhaps get an ISBN (for the quick start guide in the box) and use the ISBN based barcode on the box. I see plenty of kids magazines with ISBN or ISSN and lego bricks attached, so this would be no different logically. It would be a unique product code, and allocated to us, and as it is a one-off fee for ISBNs, no annoying recurring fees. As a bonus, no dealing with the stroppy people at GS1 either. If ever we do a deal with a retailer I'll ask if an ISBN based code is any issue for them - I doubt it some how - it is, after all, just a number in their database.

It is rather amusing that GS1 felt some legal rights existed in the allocation of these numbers. They must know that no such rights exist, but still assert they control them in their documentation!

Another interesting case which we see quite often is MAC addresses.

These have to be unique, on a LAN. In practice the way to do this is to make them unique in the world by a central allocation of the OUI (first 6 characters / 24 bits) by the IEEE who charge over $2000 (one off) for such a prefix. We have paid for a prefix and use it.

But what we do see is some times people just make one up. This is partly because there is loads of unused space in the allocations so easy to pick one that is spare, and partly because the actual chance of a clash on a LAN is very very low even if some other manufacturers is using the same prefix. So devices with unregistered MACs exist. AFAIK there is nothing the IEEE can do about it, as, unlike many things, there is no need to join a club or contract with other users of MAC prefixes where you may be obliged to have a "proper" prefix.

Am I right that there is no generic legal right to numbering allocations?

No, you hang up!

I was pondering a little on the evolution of the English language through texting and emojis...

Things are changing, and even before texting there was the issue of "ending" a conversation. Someone can always have the last word.

I have found that the iMessage feature to tag a post with a thumbs up/down, heart, haha, etc, is actually perfect for this. Someone makes what seems like the final comment and you "thumb up" it. There is no real response to that.

Whereas if you say "Thanks" and close the app/window, they may pop up again with a "Thank you too" or "No problem", etc.

But the idea of a "thumbs up" like this does not really fit previous normal language. People don't really do that in real life, or if they do they seem strange (even if that does end the conversation).

Even so, I find myself at a loss when using a different app that does not have that feature.

So we are all stumbling in the dark working out the new etiquette and language. It is exciting times.

How do we explain: Maths does not work like that?

Once again...

Theresa May is asking for back doors in encryption (here).

"These companies have some of the best brains in the world. They must focus their brightest and best on meeting these fundamental social responsibilities."

I don't know how many times we have to try and explain that mathematics does not work like that. You cannot make a way to decrypt something only when there is a valid warrant issued by a judge. Maths does not understand judges or law. The only way it could work is if someone, somewhere, on accepting the warrant as valid, uses some back door that has been built-in to allow access.

Even just that one person, as if it would be only one person, could, on a whim, for their own amusement (or because criminals are paying them enough to move to a new country) decide to do the thing they would do if presented with a valid warrant. That person has means to hack in to encrypted communications - they have to have in order to enact the warrant, so the encryption is inherently flawed to allow that.

The system only works if there are flaws and back-doors, and no matter how you try, these will be exploited by criminals. Simple as that.

So my thought is how the hell do we explain this to politicians.

They are using "passive-aggressive flattery". They are saying we are smart and so surely we can work it out.

Well the same applies to the politicians, surely. They are smart. Surely we have some of the best brains in politics and law making. Surely they can just "make a law" which somehow only applies to "terrorists" and bans them using encryption and is a workable law that they will abide by. This leaves the rest of us the protection that strong encryption affords, but allows the government to see the communications of terrorists. Simples!

Surely they can make a law that would do that? They just need to get the best brains in law making together to focus on making such a law. How hard can it be?

I am no law maker, but surely this must be possible. And I will refuse to accept the comments from anyone being so negative as to suggest that "that is not how law works". They are just not trying hard enough.

Just make an effective and workable law that bans all terrorists from using encrypted communications. How hard is that? Do it!

Go on then? You have a civic responsibility to make such a law, get on and do it already?

When is "next day" not in fact "next day"?

Technically, the rant is not that much about DHL, it is about Plates For Cars, a company that print number plates. You can work out why I am in touch with them from previous block post. Top tip - normal acrylic plates from Halfords do not fit the plate holders on a Tesla, you need the metal (thinner) ones!

The ordering page is good, lots of sensible options for style of plate, badges, etc, shown clearly graphically. Very impressed with that bit.

When you get through placing most of the order you get to a page with loads of options for plate holders and screws and all sorts which you scroll past and click to continue, and then to a page with this image followed by a continue button.

On seeing this I immediately took the message that ALL ORDERS (so obviously including mine) are shipped with DHL which is explained as Next Day to UK & Ireland and longer for outside UK. As I'm UK I took that as my order will be Next Day. I was pleased and clicked continue.

This is where my first disappointment comes in. The smaller print above this large and very clear graphic says when I can expect the delivery, had I noticed it. I did not, as the graphic was so clear. They don't ship same day, they ship the next day when they have made it, so it will always be at least TWO WORKING DAYS.

The bit I had not noticed was that there is in fact a choice of DHL Economy or for £2 more, DHL Express. Economy (the default) is 3 to 4 working days away and Express is 2 working days away.

So why hit me with the big graphic saying ALL ORDERS and NEXT DAY when neither is true!

So, bad website design and wrong (lying) graphic. Even allowing for time to make the plate it is either not "All orders" or not "Next Day" for (all) DHL. It is a choice of next day or not, after a day to make it.

Now we get to DHL incompetence, which I have come to expect, and email saying :-

"Your DHL EXPRESS shipment with waybill number 8316007442 from PLATES FOR CARS LIMITED is on its way and will require a signature."

Hang on, that says DHL EXPRESS, which is the "Next Day" option. Wow, good...

It goes on to say expected delivery Monday, which is not "Next Day".

So I wonder which lie it is? Is it not DHL EXPRESS, or is DHL EXPRESS not "next day"? There is at least one lie in here somewhere.

Very annoying, hence the rant.

P.S. They did not fit properly either :-(

Custom (UK mainland) car number plates

My previous blog on DVLA paperwork sparked an interesting debate, so I though I would say more, summarise some of the issues, and expand on them.

UK car number plates have gone through a lot of changes over the decades, and living in the UK, we mostly know these. Those from other countries may find some of it odd. AFAIK places like the US have different systems. In the UK the plate is UK wide, not state wide or county wide, and managed by the Driver and Vehicle Licensing Agency. Normally the plate stays with the car, unchanged, forever. There are regional aspects to some of the lettering used in some cases. So a few points on UK plates generally before we start. There are cases that plates can be re-assigned to new vehicles though...

First off, they are in various fixed formats. Unlike some places where you can have almost any word you like, the UK has some fixed formats, but some of these are quite old and can still be used.

Some really old plates were numbers and/or letters. I don't know the exact formats, but a plate of A1 is still valid, and it's a Black Mini, apparently. Wikipedia has a detailed history (here).

To use an old plate it has to have been transferred from the originally assigned car over time to the car it is on now. They are not issued new. It is possible to assign to a "retention certificate" and then back to a car though, within time limits.

Then we have plates of this format, a three letter code, a number from 1 to 999, and a year letter.

Again, these are not issued new, so only exists if transferred from car to car. I passed my test in that one.

The three letters were partly an area or region. The number was arbitrary.

Then we have more modern plates, which are simply the other way around, year letter, number 1-999, and three letters...

That one is white Porsche. I am not surprised. These can be purchased new still as cherished plates. Many nice ones are up for auction.

At this point, or around then, DVLA started to hold on to numbers 1-20, 100, 200, 300, and 111, 222, 333, an so on, as "special" and sell them separately.

The year letter used to change each year and the motor industry managed to push it forward until it was like August, and then complained that all the sales were in that month for the new plates. The fix was two letters a year, which used them up quickly.

Then we have the current format, which is two letters, two digits year code, and three letters. The year is last two digits of year or that plus 50, so two changes of year code a year... E.g. this is 2017.

This was, until a few days ago, a Tesla...

By the way, the font, size, colour, and spacing is now strictly controlled, which never used to be the case, and some really old cars are still allowed to show plates in the old format. There days, front plates are black on white and rear are black on yellow.

So, with this latest format, it is quite hard to make a plate look "custom". Not all letters are allowed. Only year codes that exist so far and that are older or same age as the car, are allowed. So limited. If you can spell something, that is likely a reserved and very expensive plate.

So I went for something simpler for James's Tesla. This is not his plate, but same idea. Why not make something that looks uncommon / unusual and even better if it has some meaning. E.g.

Sadly they don't do "OOO" as the letter codes, and the space is required, but this is "8" in binary, which is what the "B" means. There are actually several ways you could make a plate of this sort of style, and the number of "O"'s and "I"s in it make it look "special" I think. Am I wrong. Does this look like any random plate or something special? That plate is actually still available for £499 if you want it, James has something similar. I think we have achieved the "special" and "obviously custom" with this plate. I hope so.

Printing plates

Now, when James got the paperwork, I blogged how silly it was as he assigned it on line. What was amusing is they sent a PDF with a background image as a certificate to take to the place making the plates. They need this else they could be in trouble.

The issue is that it is just a PDF, could easily be edited to any plate you want.

Also, for no good reason, it had to be used within 3 working days and no duplicates would be issued?!?! Again you could edit the date. But I assume they feel that within 3 working days you'll have a new V5 that you can use to get a new plate anyway.

But go on-line and you can order any plate, valid or not, in a matter of days for the same price as halfwitsHalfords. I think they print in another country to ensure compliance with the law!

I did suggest he had them fit the plate, if only to fuck with the car parking at The Point, in Bracknell, which is all ANPR based there, free for 2 hours. He would arrive with one plate and leave with another, and when he gets a parking fine he has every valid reason to dispute it. He was not that "adventurous" sadly.

Sadly the plastic plates were too thick to fit on the Tesla, so some embossed metal plates are on the way, from the Internet, without seeing the fancy PDF certificate!

Problems

OK there are a huge number of issues with "cherished" plates in UK, and my last blog highlighted these a lot. The biggest issue is around the logical "ownership" of a plate. (some of these taken from anonymous poster on my blog).

• If you buy a plate that is not currently on a vehicle and is held only on a retention certificate then DVLA will not change the name of the owner of the plate. The certificate will still be in the seller's name and you as buyer will just be listed as someone who CAN put it on to a vehicle, but not someone who owns it. Years later, thinking you own the plate, you could go to put it on a vehicle and find that the previous owner re-sold it and DVLA allowed this as you had not yet exercised your right to put it on a vehicle so DVLA still had it down as owned by the person who sold it to you years before.
• If you want to eliminate that risk then the only way to get your name listed on the DVLA paperwork as the plate owner is to put the plate onto a car and then immediately take it off again whilst specifying on the "take it off again" form who the new plate owner should be. DVLA will then issue a retention certificate in your own name. If neither the seller nor buyer of the plate have such a vehicle available then changing the name of the plate owner can't be done
• If you put your own plate onto someone else's car (employer's company car / boyfriend's car, etc.) then DVLA consider that the registered keeper of that car now owns that plate and you as true owner lose all rights to that plate from that moment on. DVLA will allow the employer/boyfriend to sell that plate without any reference to you. Never put a plate on a vehicle unless you are the registered keeper of that vehicle.
• If your car is written off, your insurer will be wise to this and will try to steal the plate using this method as soon as they become the registered keeper - get the plate taken off the car before the agreement to settle the claim and write off is made and before you sign over the car (or it's remains) to the insurer
• You cannot apply a plate to be assigned to a car that has had any break in vehicle tax or SORN in last five years? The issue is that if you buy a car, how do you know that? It is not, AFAIK, on the paperwork, and also not your fault so why are you penalised by not being allowed to apply your plate to your new car exactly? Indeed, DVLA site says that you need 5 years unbroken tax/SORN so implies cars under 5 years old cannot get a new plate - thankfully the DVLA web site lies on this point. James has his plate assigned to a new(ish) car.
• If it is deemed that you misrepresented the plate (incorrect font, size, spacing, etc) you can lose it!
• Occasionally insurance companies (and ANPR based carparks) get confused by a change of plate. It was even suggested insurance companies may charge for change of plate, which is odd, as surely it is a matter of fact of which you are obliged to notify them and under data protection law they are obliged to record a change (for free).

So basically, a mess. A proper "entitlement" to a plate would be a good thing to be able to record and allow to be transferred. It is quite strange that we have this mess.

So there you have it, UK plates, pitfalls and issues...

We need something better than TPS and current legislation

I really wish, like late payment penalties, there was a simple defined civil charge one could make, sue for if necessary, for someone wasting your time with an unlawful unsolicited marketing call. It would be death by a thousand cuts as people, like us, would simply make claims. The courts would not be involved much, just the couple of times to prove the point to the idiots, and then they have to cough up for each claim without the threat of court.

We got one today that shows the problem quite well.

This is the call: mp3 (note this is stereo, one person on each ear).

The caller was, apparently, Black Sheep Utilities Ltd, selling water supply. They have been in business around 7 years, so really should know better. They called us, FireBrick Ltd.

So, some things wrong with the call...

• Claims not aware he called a TPS registered number, but later says he could not have made call if we were.
• Says they check data with TPS, which clearly they do not! That suggests he is just lying.
• Says you have to re-register every six months, which is wrong. The TPS say every 12 months, but actually the legislation does not require re-registration. We are registered permanently (as I threatened to sue them and OFCOM if they de-registered us again, many years ago) and I double checked and the number he called is still registered even now.
• He suggests that if you go on line, your number will be "attached to your IP" somehow.
• He suggests we may have left a "your data will be shared" tick box ticked on the Internet.
• No remorse whatsoever!
• He says if we were on the register he would not be able to call us, clearly that is a lie.

This all seems a bit confused. If they screen for TPS and don't allow calls, then how is having a "your data will be shared" tick box relevant. Clearly they don't in fact check against TPS as we are on it.

Until there is proper action against such people, they will just waffle their way through such calls and ignore their responsibilities. We all pay the price in huge amounts of wasted time.

Also, he seems confused over "details being shared" and the unlawfulness of unsolicited marketing calls. It does not matter how much our number is shared, and I would not be surprised if the number is shared, it is on our web site even, and companies may know it. I have no problem with the number being shared to people that may be interested in buying FireBricks. That is why we have a number, so potential and actual customers can call us. What matters for this is that we have not given him permission to call us for marketing. Even if we gave permission to someone else, and gave them permission to share our details, unless we gave Black Sheep permission then his calls are unlawful.

What can be done to sort this, really? The ICO will not be interested, I am sure.