This question seems critical to uses of Tor hidden services that run on a host with intermittent connectivity (e.g. http://ricochet.im on a mobile device). CC @SarahJamieLewis
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Even without digging into the protocol details, it's difficult to imagine how they wouldn't be vulnerable to such an attack at at least the active attack / active connection attempt level.
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Generally speaking, the only thing that can thwart guilt-by-association in a scenario in which a third party can subvert the communication path toward the suspected endpoint is randomized selective non-response to inbound traffic...
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They don't have to activity subvert. I'm assuming surveillance apparatus with full cell-tower connection status logs for everybody in the threat model.
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You still have to have fairly frequent periodic inbound communication attempts to which a response would be generated if the device and software were online to begin building correlation to a given party, and so while active interruption may not be required, active testing is.
End of conversation
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