Comma is a company that has made significant advancements in self-driving technology. Their guiding principle is to do more with less while remaining completely transparent; to say they are transparent is an understatement. Perhaps a better descriptor would be "down to earth." It is an open source platform with a considerable amount of community backing. They have disrupted the self-driving market by introducing an aftermarket device that can convert almost any modern car into an L2 self-driving system. 

Despite an incredible accomplishment and the recent release of a brand new hardware, they appear to be having cash flow problems.

What follows is my take on how I would approach this issue in order to appeal to a broader audience rather than just developers.

Why does Comma lack visibility and financial viability? 

I believe the issue is becoming clearer to me. When it comes to marketing and mainstreaming the product, it appears that Comma is caught in a Catch-22 situation. (I'll explain in more detail later.) 

Let's apply George's "Input - Computation - Output" logic. Assuming the goal is to become profitable by mainstreaming the product. I'm going to categorize these three parameters as "Core Actionables."

INPUT: 

• Brand Image: This is clearly a one-of-a-kind self-driving product with a tremendous value proposition. Even at its $2k price point, it outperforms Tesla in terms of value. A typical Tesla costs between $40k and $50k, plus a $12k FSD. As a result, the Comma must stand out. 

Comma Pros.

• A 360° Dashcam.
• Can add xxx number of automobiles into autonomous driving vehicles (L2, 3 ,4  whatever arbitrary “L” as defined by the industry).
• Over The Air updates.
• Open Source (MIT License) and user customized forks.
• Drives like a human would.
• Hands free steering with DM.
• Constantly Evolving (AI).
• Added Safety.
• Engineered and Assembled in the USA! (This could be variable) 
• Strong community support.
• In many aspects, better than Tesla’s AP systems. 

Comma Cons

1. DEV KIT: This is the most significant issue that I see as a major impediment. The problem isn't with the device or the price. The main problem is market penetration. Comma's reach as a developer kit is extremely limited. How many users are familiar with the SSH protocol, Github, LKAS, OBD, and so on? As a result, the product is extremely niche and can only appeal to a very small demographic. Comma may increase sales by x number of percent, but how long will it last? Assume, hypothetically, that Comma releases a Comma3 as its first device as a dev kit for $3k; there will be a lot of sales initially, but it will eventually plateau. As the case may be, the same is true for Comma2. So the main problem isn't pricing and selling a consumer electronics device with a 50% gross margin. The main issue is sales sustainability.

2. BETA: Tesla can utilize this and may be able to get away with it. However, in my opinion, the term can be used interchangeably with computer software, but NOT when it comes to operating automobiles. As a customer, I wouldn't want a BETA operating my vehicle. The word "BETA" or "ALPHA" should not be used anywhere near this product; it needs to be robust.

3. NHTSA: This is where the catch-22 situation enters the picture. Comma can use terms like "Dev Kit," "Beta," and "Open source" "for research purposes only" to get around the regulations, but this also limits its ability to become a mainstream product. When it comes to politics and regulatory controls, it makes no difference what their personal philosophy is. At the end of the day, Comma is a "Company" operating within the realm of capitalism, and the "Fed coin" is the only resource that will keep it afloat. This is an ideological conflict that must be resolved at some point. Both cannot exist at the same time. If it wants to play the game by becoming a legitimate organization, it must follow the rules of the game.

4. OUT OF THE BOX USER EXPERIENCE: This is pretty much covered in what I stated above.

5. OEM FIRMWARE LOCKS: Assuming that Toyota’s and Honda’s are Comma’s primary bread and butter. With Toyota locking their firmware for all their future cars then 50% of its future potentional revenue for new cars is already lost (50% is a number I am using for arguments sake). Even if the Toyota firmware exploit is discovered; how long will it take for them to patch it again? This now becomes a classical definition of a Cat and Mouse game. Also with more and more car manufactureres aiming on going the “Subscription” based model, who is to say that other manufacturers won’t follow suit? Comma is a legitimate company which I am hoping is aiming to become a billion dollar organization in the future. How can it achieve this goal by being perceived as a “hacker” mentality organization by the mainstream industry? Which brings me to the next and final con.

6. GEO HOTZ: Elon Musk has a questionable past, but he is a fantastic showman. In comparison, George is far more honest, hardworking, and forthright about his ideology, but the majority of the population does not see it that way. Unfortunately, Geo Hotz is synonymous with the term hacker, which has a negative connotation. It is a regrettable situation, but it must be addressed.

COMPUTATION:

1. NHTSA: Establish a budget to implement appropriate regulatory certifications. There are numerous user driving metrics and data that can be utilized as proof (I am not a lawyer, but I think the evidence is unequivocal)

2. LIABILITY OFFLOAD: Openpilot is very stable, even at version 0.8.14. Remove the words "BETA" and "DEV KIT" from the devices and replace them with end user agreements that outline the device's limitations. (Lawyers may be useful here.)

3. PRIVACY OF USERS & DATA COLLECTION: Particularly with the interior 180° cam view, consumers may have very different opinions of this policy, so be very explicit about it. It ought to be stated in the end user agreement (Again, Lawyers)

4. ELI5 IT: If the user must perform the installation, make the instructions as clear as possible. A good idea would be to include a link to the installation videos for each supported vehicle. If possible, follow the IKEA method with the instructions in the box. Remove SSH and Github and replace them with a simple OTA.

5. EMBRACE THE HACKER: Since every other media piece begins with the phrase "This hacker invented a device that can drive your car," it is time to embrace the hacker. If necessary, address it directly in a favorable spotlight. Numerous outstanding technological innovations have their roots in hacking and are inspired by it. For instance, the Apple 1 wasn't the company's first computer. The first product created by Steve Jobs and Steve Wozniak used DTMF tones to breach the security of AT&T pay phones.

6. JOIN EM: If necessary, bite the bullet and bring at least one OEM on board. Take the Mobileye approach. This will provide Comma with much-needed industry legitimacy.

7. SIMPLIFY: Promote it as "A dash cam which can also drive your car" rather than "Android of self driving." What a cool thing!

OUTPUT:

1. DIVERSIFIED PRODUCT LINE: Having addressed the issues raised above, Comma should be able to keep the open source platform and ship Dev Kits while also dividing the devices for non-technical consumers with less expensive hardware. A good example would be hardware tailored to each tier, such as Gold, Silver, and Bronze supported vehicles. This has a much bigger value, for example, if I have a Bronze car, why would I want expensive hardware designed for the Gold tier?

2. SUBSCRIPTION BASED MODEL: In addition to a steady stream of revenue from OEM licensing, a subscription-based model like Comma Prime with additional incentives would make revenue more sustainable. Some of the profit margins from device sales can also be subsidized in order to attract more customers.

3. SUSTAINED: Year-over-year steady income with much higher and wider market penetration. Organic expansion of xx%

Conclusion: The ultimate goal of Comma is to solve AI. If I were them, I would go through any means necessary to achieve that goal. All of this can be accomplished using their existing Lean principles, such as maintaining low overhead costs, a small marketing budget, and remaining a technology-led organization. What they have accomplished thus far is nothing short of revolutionary. 

They have an extremely robust product developed by a small team of engineers that could serve as a case study for the entire business industry. Instead of being portrayed as outsiders attempting to disrupt the industry, they simply need to market themselves as "what they have to offer." They have already disrupted it; all they need to do now is step "in" and get the credit they deserve!