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I prefer to stay grounded in the reality of how the world works when responding to questions about legalities.
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What you said isn't true for quite a few countries.
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That's quite possible, but could you name a couple where locking a raspberry pi type of computer would be illegal?
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EU Right to Repair Directive specifically prohibits manufacturers from using HW/SW locks or firmware limits to block part replacement.
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The part replacement isn't being blocked? The OP's CM5 with replaced RAM is still a working CM5 according to him.
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The part can be replaced with the same part to repair the item. This is not locked.
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Part locking against unoriginal parts is prohibited in the EU.
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"Each chip is programmed with the timing settings and storage size settings of just the RAM we ship it with, and doesn't know how to boot with anything else." I don't know if you could call that "blocking." I mean you could call it that but I don't know if that's legally what it would be.
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