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Comma 3X (comma.ai)
101 points by Yenrabbit on July 30, 2023 | hide | past | favorite | 93 comments



I have the original Comma 3 in my car (2019 Acura RDX), and it's pretty game-changing for long drives. The car already has adaptive cruise control and lane-keep-assist, but you need to keep your hands on the wheel. With the Comma, I can set it up on most of the roads I drive (local or highway) and it'll keep me going at the desired speed in the center of the lane (up to a certain max turning torque, which is a limitation on the Acura LKAS system - if you're in the Bay Area, it handles 101 just fine but will struggle on the 280).

I've logged about 3k miles of autonomous driving at this point and wouldn't hesitate to recommend it if your car supports it, with the understanding that it's a limited system and you still have to pay attention the entire time. Unfortunately, it seems like a lot of the newer cars have tighter security around CAN bus communication, so it may not be easy for Comma to continue to do their thing.


It's also notable to point out that OpenPilot is way smoother/better than stock LKAS (and otherwise), and getting better with each release (based on personal experience in Toyota and Honda/Acura cars).


Is there any reason for CAN bus security, other than preventing people from modding their cars?


The wiring for the CAN bus can be made to be accessible from the outside of the car with a bit of force, which means that's all a thief needs to do to steal your car. Yank a headlight out until the wiring harness comes with it, making the CAN bus accessible, install the car stealing modchip onto the bus, unlock the doors, get inside, start the engine, and drive off.

https://www.autoblog.com/amp/2023/04/18/vehicle-headlight-ca...


There is a new unece regulation, requiring strong temper protection, which means at least CAN authentication. https://unece.org/sustainable-development/press/un-regulatio...


I'd imagine the anti-tampering clause (it's a felony!) of the Clean Air Act is one reason.


There really needs to be more regulation with products like this.

As a start transparent disclosure of their safety record, a restriction on shipping the product to countries where such devices are not legal, clarity on how the device behaves under adverse conditions e.g. rain/snow etc.

Comma selling this product like it's some car accessory looks pretty reckless to me.


Why people start to cry for regulation whenever they see something new these days? Hasn't been the case before, something has shifted in people's minds in the last 10 years or so


The leading causes for 'unintentional injury' deaths in the USA (age 1-44) are:

1. Drug overdose

2. Motor vehicle traffic

Maybe there is a need for regulation? Especially if you consider that the USA has 2-4x more road deaths per million people compared to europe. Safe technoligies through regulations are one aspect in addressing this problem.


> The leading causes

Did you just make my point? Drugs are already very regulated.

> Maybe there is a need for regulation?

Probably not.


Apples and oranges.

Road safety is increased in countries with more regulations - there is direct evidence across the (developed) world.

Drugs is an entirely different problem that has way more factors that make comparisons between countries rather difficult.

And just because drugs are regulated AND an increasing doesn't mean that the problem is resolved by less regulation. Maybe there is just a need for different / adjusted regulations.


> Drugs are already very regulated.

Enforcement is lacking, incentives for criminals are extremely high - cocaine, for example, explodes in value from $2000/kg in the jungle where it's made to $20000/kg after it's been smuggled to the US - and quite a few popular drugs can be made at home using basic tools and skills (cannabis, amphetamine, alcohol, tobacco).


Enforcement isn't lacking, it's just done counter-productively. About 20% of US prison population is already for drug offences, and of course it doesn't help anything. There is absolutely no reason to believe that other regulations are or will be enforced in a smarter way.


Do you believe there will be fewer deaths if existing legal drugs were unregulated?

Edit: Clarified it’s about existing legal drugs, not illegal drugs.


No one is advocating for no regulation at all, but there is evidence on how limited regulation and not putting people behind bars for consuming even hard drugs like heroin is actually benefitial and results in fewer deaths, look up what happened in Sweden.


Clarification- I didn’t think they were referencing illegal drugs, rather I believed they were talking about regulations to bring medical drugs into the market. Eg cancer drugs etc, which have to go through rigorous trials and validation first.


People are extremely risk averse nowadays. The same way children could play outside alone before, and can't now.


.... Because of cars...


No. It’s because of shifting standards. The “can’t play outside” applies just as much in places with no more cars than there were 40 years ago (or even no cars at all for most kid -> playground routes)

The town I grew up in has, for 95% of kids, no more than 3 internal, slow roads to cross on the way to school. There’s more traffic, but only slightly so - most cars drive away from town, so despite much more traffic in general, inner roads are only slightly more crowded.

And yet, it was perfectly normal for me to walk to school 40 or so years ago as a 6 years old, and it is now illegal for anyone under 9 to do so.


Yes. It's because the city I raised my kids in had cars speeding everywhere, including residential areas, running red lights and stop signs constantly and when a driver killed someone with their car, they were on the road the next day with no consequences.


In the 70s and 80s there were cars everywhere, pedestrian fatalities were even higher than now. Yet kids played outside alone. So it's not that.


Sure, it's multifaceted. But pedestrian fatalaties have gone down at least partially because children walk to school less often, in a reaction to the huge number of pedetrian killings of the past.


If we're using anecdotes, cars are the reason my kids don't walk independently, and the reason we're moving to the Netherlands next month. Drivers are the leading cause of dead children in the US.

Aside from directly killing children in impacts, car dependent design is usually hostile to walking anyway, for adults as well as kids. Walking to school is nice, but challenging when hundreds of parents late for work in tall, poor front visibility SUV's are running stop signs on the same streets where your child is walking.


Exactly the same for me. One of the main reasons I moved my family out of the US.


Where to? Moved to Ireland ten years ago, moving to Netherlands next week, mostly for kids.


> Why people start to cry for regulation whenever they see something new these days?

Maybe because people care about other people instead of their tech bro cool tech feelings?


because this is a device installed in two tons of steel moving around at lethal velocities in close vicinity to human beings who didn't sign up to be unwilling beta testers. If anything 10 or 20 years ago this wouldn't have even made it on the streets.

Can you imagine a factory where machines with the potential to dismember someone are installed by amateurs with no certification? This is like that except factory machines don't drive next to school yards.


>Can you imagine a factory where machines with the potential to dismember someone are installed by amateurs with no certification

I've got some bad news for you about human drivers, they're typically allowed to get a single certification as a teenager that lets them operate a motor vehicle for 50+ years with no recalibration other than maybe a decadal vision test.

We inspect elevators more often than human drivers, despite elevator deaths being much more rare (maybe that's a cause and effect relationship?)


You are presenting it like "certification" is some kind of guarantee. The reality is that it isn't. Industrial accidents happen all the time and it remains to be proven that certifications and regulations actually improve anything.


Because this can kill people. Lots of them. And not just the users.


So? A shovel can kill people.


Consider how many people a shovel versus a car can kill in a minute.


I'm not sure what's your point. But the direct answer is, it's a very similar number of people, not even an order of magnitude difference.


FFS "not even an order of magnitude".

As another commenter linked, cars can kill at least 86 people at once: https://en.m.wikipedia.org/wiki/2016_Nice_truck_attack

Please share any instance where a shovel was used to kill even 8 (let alone 86) people in under a minute.



I am pretty sure that it was meant "unintentionally". I would say that nobody has killed another person with a shovel unintentionally since shovels exist (maybe injure). OK maybe one since shovels exist /s


https://en.m.wikipedia.org/wiki/2016_Nice_truck_attack

Really not sure you're correct here.


Note: 'can kill' >= 'has killed', you have only shown the latter.


Don’t feed the troll.


Come on, in the end it's the driver that's responsible. It is in fact a "car accessory".

Calling for "more regulation" will blow out small companies like comma ai out of the market. It's a miracle one can get stuff like this for older cars. If big auto manufacturers had their way you couldn't change wiper blades without buying a new car. As someone driving an 18 year old car I hope there will be more companies like comma ai. (of course my car is too old to use with comma).


Come on, in the end it's the driver that's responsible

It's not always the driver who's the sole victim of driver irresponsibility.

Protecting those others are what regulations and laws are for.


> Come on, in the end it's the driver that's responsible. It is in fact a "car accessory".

I’m sure victim (or their relatives in case of their death) will be relieved.

> Calling for "more regulation" will blow out small companies like comma ai out of the market.

Will someone think of my cool tech startapperinos?!


> Comma selling this product like it's some car accessory looks pretty reckless to me.

Comma is not selling openpilot (the software that makes your car self-driving), but they are selling the Comma devices that out-if-the-box just include dashcam functionality and a few additional features.

Openpilot is an open-source project on Github that makes cars self-driving and that also runs on regular Linux PCs as well as those Comma devices.

Do you suggest that Comma should not be allowed to sell the Comma devices anymore (that out of the box work as a Dashcam)? Or do you suggest that Comma should not be allowed to contribute to an open-source project that can make cars self-driving?


> Comma is not selling openpilot (the software that makes your car self-driving), but they are selling the Comma devices that out-if-the-box just include dashcam functionality and a few additional features.

Come on, this line of reasoning pretty clearly can't work in a lawful society.

Imagine Smith & Wesson making the argument that clearly this gun is just meant for decoration, we can't be responsible for people buying bullets on our webpage and shooting people. That's clearly a bogus argument. It's legal obfuscation.

If comma didn't want people to run openpilot on their dashcam, they wouldn't host a guide, the wouldn't market it, they would lock down the software they build. The hardware is MADE to run openpilot. Openpilot is MADE to be run on the hardware.


Firearm and ammunition manufacturers are already not culpable for people getting shot. Your argument would be better made comparing Comma 3X hardware + OpenPilot software to something that unintentionally causes injury despite being used as intended.

Then again, if you used that line of reasoning you'd have to show a comparable example of OpenPilot unintentionally causing injury, rather than just waving your hands and saying "it COULD happen, because unregulated!"


So, the way you phrased it made me believe that this "openpilot" software is unaffiliated with Comma.ai. But they are, in fact, the owners and maintainers of the openpilot repo and link directly to it on their website.


I didn't mean to say that they are not the owners, but that those two items (Comma devices and the software) are two different things.

Yes - Comma owns that repository and there are instructions on how to put the software on Comma devices. But then also lots of commits are from authors not affiliated with Comma and my understanding is that quite a few users of that software aren't actually using the official repository, but various forks maintained by third parties.


This isn't a serious argument. Comma trains the model that OpenPilot uses. I doubt anyone else has trained their own.


From Comma's website:

"Meet the comma 3X The comma 3X is custom hardware designed to live in your car, and purpose built to run openpilot. The comma 3X has three beautiful HDR cameras, two cameras to watch the road and one night-vision camera to see inside the car. "


"and purpose built to run openpilot" would be the main issue here. Everything else is also required by a regular dashcam. The legal question here would be (and I don't know that answer to that) if someone distributing a hardware device that's optimized for a particular functionality without shipping that functionality, would be liable when users manually add that functionality to the device.


IANAL, but I don't think there's nearly enough insulation here.

I don't think there's much distinction between selling someone a device and then giving them free software that they need to install, and just giving them the device with the software installed.

Imo as long as they intend for the customers to install the software they're responsible, so I don't know if there's anyway in my mind for them to make both the software (or have an active role in developing it) and the device and not be liable.


"t should be noted that no ethically-trained software engineer would ever consent to write a DestroyBaghdad procedure. Basic professional ethics would instead require him to write a DestroyCity procedure, to which Baghdad could be given as a parameter."


You are already responsible for whatever your car is doing, regardless of how it is driven. What additional regulation we need?


Regulation making you responsible for reckless behavior before you cause an accident.


We have that. Drivers are responsible for the outcomes of their driving with licenses, insurance, a legal framework for operating vehicles, and even uniform enforcement.

What else would you add?

Adding a technical stack will lead to court cases but our current system can accomodate — we already have tons of driving modifying systems in cars and nobody blinks an eye.

The only reason this is even controversial is that it’s third party and not provided by the manufacturer.

I would suggest that we are good! The current regulatory compliance and enforcement system can accommodate this change.


Why bother with drink driving rules if we already have laws against reckless driving?

Is it not fundamentally the same? If not why not?


The biggest question I see is insurance coverage. I could imagine insurers moving to not cover accidents during the use of aftermarket systems like this in the same way they won’t cover incidents during track use and the like.


If responsibility substituted for regulation, there'd be no car regulation at all, would there?


I described some of the regulation we need.

People buying these devices are simply ill-informed about the risks that they pose to other drivers and pedestrians because companies like Comma deliberately withhold the information.

And given innocent lives are at stake the onus should be on being cautious about technologies like these until they are proven.


You are right, they are not informing you during the buy process on their website but there is a tutorial you have to follow interactively, which makes a 100% sure you understand the risks and limitations. It is not like Tesla at all.


I'm pretty impressed we haven't heard about more crashes...

https://www.reddit.com/r/Comma_ai/comments/u9o1mm/my_first_a...


The kind of person who would buy this would know more about its limitations than your average Tesla owner.


Eh, maybe a little. But I think most people on this website could buy this but they are clearly incapable of understanding the limits of Tesla's shitty AI. The reasons we haven't heard much about accidents with this are (1) they have like orders of magnitude less users than Tesla and (2) nobody gives a shit about this little company and so media doesn't rush to talk about it.


I'm guessing no-one will give a shit about the company size when first there's a death. We'll see.


More to the point, the kind of person who buys this would not want more known about its limitations than your average Tesla owner.


What if I buy a used car that has it in it already?


It's the kind of thing the owner would probably keep for themselves when selling the car. It's fairly easy to uninstall - just unplug and remove a windshield sticker.


What's the difference between this and the previous version?

Edit: looks like no more user upgradable storage via m.2, but it's a bit cheaper. It's also no longer necessary for some vehicles to have a Raspberry Pi sitting between the car and the comma


Wow I wasn't aware comma.ai came this far. I also wasn't aware that modern cars provided interfaces to steering/braking. Handy that!


It says 360 degrees vision with 3 cameras. How does that work? It doesn't show anywhere where the cameras go. I don't understand how you can get 360 degrees just from a device on your windshield.

I find the website so lackluster. There isn't even a picture of what it looks like from the other side.


One on the right, one on the left, one behind, all pointing 120 degrees relative to each other?


Tres commas?


Nice reference, I assume it's about the show Sillicon Valley? Was it a branded bottle of Tequila? Actually looks like some company is now actually selling it


Tres Comas was the tequila company owned by Russ Hanneman in the show. For those who have not watched Silicon Valley, Russ Hanneman was based off Mark Cuban.


Problem is, as a private user I don't want it. Now they have support for vehicles by MAN, and that cam become an explosive growth market far them.

Strangely they walked back storage space. There used to be a 1 or 2 terabyte ssd/m2 storage option.


Doesn't seem to work with Teslas, thought it would be an interesting thing to turn on both at the same time: battle of the robo-drivers. Missed opportunity, if you ask me.


There's _some_ community support: https://tinkla.us


https://tinkla.us/t/tinkla_buddy

"It is so amazingly powerfule that I can not release the source code, nor can I give you hints on how it works. As a cybersecurity expert (in my real life), I can assure you I take security very seriously. So a no is a NO."


What can I say? That was persuasive, I'm convinced.


It's a very interesting product, but I'm not brave enough to install this in my own car.


I can't believe you're allowed to. Are these illegal? Some states must have almost schizophrenic laws. Tires an inch too wide? Get that deathtrap off the road. Bleeding edge third party sensor and control package for autonomous driving? What could go wrong!


So the same projects that come from manufacturers are ok? But third party systems built by our best and brightest are bad?

Or is all driving augmentation bad? Because honestly, based on the data, humans are frequently worse drivers than the absolute worst of these systems.


I didn't say any of that.

My comment is about how surprising it is something like this might be legal when other, very benign modifications are not. That was all. A whole lot more can go wrong with something like this, versus say an aftermarket exhaust.

The regulations are not hard to know, but something like Comma is a little bit in front of the regulations, and so it poses risks we have yet to discover and cater for in said regs (sensors must be weatherproof might be a good example of a good reg). The same is true for OEMs, Tesla and friends were bringing out features faster than regulations can describe if they are safe or not. This is not true for other parts of vehicles, we understand suspension safety very well so just following the regulations is enough to stay safe.

In general, unapproved vehicle modifications are a risk as they haven't gone through the same safetey and emissions appratus as approved parts and OEMs have. How risky is the variable, tires too wide, not very, full vehicle control change, pretty risky. I hold that opinion as an avid car enthusiast, some stuff we shouldn't fuck with unless we get it engineered and signed off as safe enough to join the driving public (and I have done this for my suspension modifications).


Fair enough. Sorry if I misread your comment!


No stress, I can see how we'd get mixed up, it's a pretty heated topic!


> So the same projects that come from manufacturers are ok? But third party systems built by our best and brightest are bad?

If only there was some kind of a set of rules that would define what is “ok”, it could “regulate” both manufacturers and third parties. We could call them REGULATIONS.


No EU distribution?


They ship worldwide. Have bought 2 devices already within the EU. Was no issue at all besides import tax.


Are they legal to use in the UK?


I would not be surprised if this would eventually be heavily regulated. It is a bit of a quiet before the storm perhaps. If you look at how heavily medical devices are regulated (I worked in medical devices) I would not be surprised.


Europe already has fairly high standards for ADAS performance to be road-legal. The Comma units don't even attempt to meet that standard. It's possible those requirements don't apply due to some technicality or that installing uncertified safety critical features in your car is perfectly legal, but I wouldn't bet money on either.


No, I think there is no country in Europe where those devices are legal. It is just difficult to prove, that you where actually using them. They are not illegal to have and I think (haven't checked!!) it is allowed to record your CAN while driving.


Usually there is no restriction in custom supplied components, which would void repairs by third parties (i.e. you). In most environments you are whoever not allowed to drive with hands of the steering wheel or if not mentioned explicitly you are not allowed to create unsafe conditions (which where I live means you have to be in control, even with driving aides)

Placing a can monitoring and loggin tool on the obd port is perfectly legal afaik. Sneeky spyware installing insurers do it all the time.

For manipulation via can: ymmv depending on what modifications need to be applied and what security is broken (if any) and you should ask your insurer what they cover. The insurance part is my biggest concern.




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