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Yes, that's accurate. It's not only behind several security patches, but lacks hardware and device security updates all the way back to August 2018. Those updates are available through Android Pie, and it was mandatory to migrate last year in order to continue providing them.
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The -05 updates are tied to the SoC platform, kernel and other device-specific code not updated via the baseline AOSP releases. Copperhead does not have these updates since August 2018. They DO NOT have even the August 2018 security update and are dishonest about the patch level.
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They resorted to doing the same thing that other ROMs have done for years: lying to their users (in this case customers) about the patch level they're providing to make it appear secure. They're aware they lack full security updates since August and are just incredibly dishonest.
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The company was unwilling to devote the necessary resources to the actual development work and became focused on selling companies contracts it was unable to fulfil. The hardened OS took a back seat to James lining his pockets and pursuing get rich quick schemes via the company.
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