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The EFF disagrees. In addition to considering this "Fair Use", they are also making a claim for an exemption based on the need to analyze the software for safety and research.
https://www.eff.org/deeplinks/2015/04/help-eff-defend-right-tinker-your-car
Good reading...
https://www.eff.org/files/2015/02/09/2014-_07_eff_vehicle_security_comment_.pdf
https://www.eff.org/deeplinks/2015/04/help-eff-defend-right-tinker-your-car
Good reading...
https://www.eff.org/files/2015/02/09/2014-_07_eff_vehicle_security_comment_.pdf