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While I've certainly heard plenty of theorizing about the possibility of this happening, I have yet to see any conclusive evidence that it has ever been done.

EDIT: What I am referring to here is the specific allegation that smart TVs will connect to open wireless networks without being commanded to do so. It's not a catch-all for any nefarious thing involving TVs or wireless networks.

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It's been confirmed in the recent LG scandal.
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The denied ones that have yet to be proven?

LG denies TV spying claims, says tracking and snooping concerns 'not true' (635 points, 2 months ago, 494 comments) https://news.ycombinator.com/item?id=49645480

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And that isn't even the same thing either! (This seems to be a recurring theme.) If it were true that LG TVs "spy" on ambient audio, that would certainly be bad, but it wouldn't also establish that the TVs were connecting to open wireless networks to exfiltrate that data.
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LG scans the list of nearby networks. It does not automatically connect to any.
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You still run the risk of a software update doing a tv to tv mesh network. You gotta own the software or remove the radio.
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How many open WiFi networks are there within range of your TV?
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Comcast runs a separate "Xfinity WiFi" on all their routers, any Comcast user can connect to it with their credentials. Would they strike a deal with TV manufacturers to let them use it? It would not surprise me.
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Pretty sure this is a known offering from Comcast, you just have to talk to the right sales rep... I haven't yet seen any evidence of a TV using it (yet), but hve been told they will sell a company IoT or fleet device access to their wifi endpoints for enough money. I'm not sure it would be cost effective for mass market device surveillance, though.

Also Amazon does this same model with their Sidewalk service, which can run over bluetooth or lora, instead of wifi... and is specifically priced to be usable for large numbers of devices.

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It would however surprise many.
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