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In my mind it's always because he played Kyle Reese once and the car was just confused about it.
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At this point, I feel like automakers should be criminally liable for redesigning the automatic shifter UX. It's probably the 3rd/4th most dangerous control in the vehicle; why do we want people to have to relearn it every time they're in an unfamiliar car?

(I stick with a manual for my vehicles, so fortunately I'm mostly immunized against the madness.)

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