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This is just one example. There are other ways it is approached. It is also part of how they make their laptops. So, if the firmware has signature verification, they'll block updating it somehow. If it doesn't, it'll still end up being blocked since components lack open firmware.
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And when "out-of-band" means attaching special debug cables to flash firmware onto components where they haven't done that, I'm pretty skeptical that it has real world relevance to users that are not just developers but developers taking an extreme approach.
It's not possible to update via OS, not from the perspective of the firmware. No one said the baseband can't receive a firmware update pushed via a cell phone tower, etc. No one said there is verified boot for it. No one said they picked components with security support.
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