About Andy's Submission to the A.P.H.I.S.

The U.S. Government Animal and Plant Health Inspection Service in September of 2006 finished a comment period regarding plans to implement a "System of Open Microchip Technology" for pets in compliance with a Congressional directive. About 186 comments were recorded at the regulations.gov web site. Comments ranged from "To all govermnent employees working on this potential progrm: Get back to work doing something meaningful!" to "May be as time progresses, the inventors and congress can come to an agreement for the chip-if sucessful-to be placed in children." (Comment numbers 9 and 36 respectively.)

Since the close of the comment period, I've found two main problems in my comment number 137, namely being somewhat too alarmist on the "hazards" of multi-chipping and at one point refering to the "FDA" instead of the "USDA". On the other hand, I think I submitted the best work-around for turning the troublesome AVID microchips into Open Microchip Technology. This particular pet recovery ID product is unique in that it is, by design, built to make reading it difficult for any animal-loving volunteer strangers who may try to return your lost pet. In effect, the Good Samaritan pet finder is expected to supply decryption secrets, in the form of a proprietary scanner, along with his bowl of Alpo. Some might claim, that such a chip necessarily must be a defective product regardless of how many proprietary Cartel scanners are in use as "infrastructure."

But my work-around for these chips operates on a contrary assumption: that the implanted chips are just fine, but their original labels are defective. The code number on the label is what the pet owner sends to his chosen registry database with his contact information, of course. The only reason a pet rescuer with a scanner that reads AVID chips by an appropriate open standard (such as my rec.pets-2005a) can't produce the code number in the registry database is that the original label was defective; it had a hard-to-compute obfuscation-type code instead of an easy Open Standard code. Pet registries are in the business of getting lost pets returned, my thinking goes, so why not have them use an "Open Code to Cartel Code" translator machine when they receive a found pet report made with an Open Technology scanner? This translator machine, made from a common AVID scanner, allows the registry to have a work-around for its defective database (full of codes from defective labels) and to turn the millions of  implanted AVID "Encrypted" chips into Open Microchip Technology chips without surgery.

The regulations.gov website is in general a pretty good argument against putting the Government in charge of keeping the pet data base. Talk about people who don't know how build a web site. It has search functions, but it doesn't work without Javascript, and nothing has a bookmarkable URL.

I am including here my Comment #137 with later additions in boldface:

General Comment:Re: APHIS-2006-0012

My name is Andy Kluck, and I'm the creator of the Max Microchip
build-it-yourself pet scanner as described at www.maxmicrochip.com. I read the
all-chip Coalition's petition dated Oct. 10th, 2005, and while I see the problem
a little differently, I have a petition for the APHIS too.

First of all, identify the problem. A U.S. company has built and sold a bunch of
Pet ID products, the so-called "encrypted microchips", marketing these as a good
way to get your pet back if he gets lost. The chips are each provided with a
label with a code on it that can be registered in a database. As a pet owner,
you can register your chip-implanted pet with the manufacturer's own registry
and/or one or more independent registries, of which there may be several
national or local ones to choose from. (Perhaps there should be a single
official database for all U.S. pets, or at least an official single way for the
pet finders/rescuers to query all the U.S. databases. But at least the number of
major registries is small enough that the finder of your lost pet could email
all of them in a few minutes. And quite possibly, the first registry he calls
may offer to contact all the other ones.) So is this product a reasonably
complete method for you to get your lost pet back? No! Because the manufacturer
has used SECRECY to make it difficult or impossible for the pet finder to
extract the original label code from the signal transmission the chip puts out.
The system expects the pet rescuer, the stranger who on a VOLUNTEER basis tries
to return YOUR lost pet, to provide a SECRET translation algorithm, to recover
the code that was on the label. And distribution of the secret algorithm has
been restricted to a rather small monopoly cartel of scanner manufacturers, none
of which currently seems interested in making a fully universal, whole-world
scanner available in the U.S.

So the "Encrypted Chip" pet recovery system's ID microchips are DESIGNED to be
hard to read for the pet rescuer. Apparently this somehow does not qualify as
consumer fraud or deliberately defective products, thereby warranting having the
operation shut down. Don't ask me why; you guys are the Govermint. It's hard for
people to see that these products are defective, because all the available pet
scanners that can read the "encrypted microchips" have the secret translator
algorithm in them, which overcomes the built-in barriers of the chips, and they
use it automatically and transparently. As I said, there is a rather small
cartel of scanner manufacturers that have gotten the secret decryption
algorithm, (Perhaps just Avid, Digital Angel Corp., and Trovan) and because
their products can produce the original label codes easily, the system's
purveyors have been able to establish a mind-set that defects lie in the
non-decrypting scanners made by non-cartel members, rather than in the pet
recovery identification chips that by design are hard for pet rescuers to read.
(The Cartel does not have a web site, so my short list of members came from early-2006 web research of which individual scanner makers claimed to read the chips. Trovan doesn't seem to sell scanners in the U.S. to any significant extent. Note that I never called the Cartel a conspiracy, or made any conjecture about its origin, or its structure or governance. Perhaps the members other than AVID joined the Cartel by being better hackers or analytical cryptographers than me. The Cartel members have a right to keep their secrets if they want to. The problem comes when chips, whose decoding requires the secrets, are sold for applications such as pet ID, where VOLUNTEER STRANGERS will have a reasonable need to decode them. Apparently only AVID is doing this, not the other members.)

(I use the terms "Cartel" and "Monopoly Cartel" interchangeably to mean, a group that exerts control over the supply of a commodity as a "Monopoly" might, except that a monopoly is only one entity, and this a group. In this case, I can't say whether there is any kind of organization to the group, and I don't allege that the cartel is illegal, or that collusion-based price fixing is necessarily involved, although some others may have alleged this in the past. For an example of a cartel that's not illegal, consider the OPEC cartel. For an example of a cartel that doesn't necessarily engage in collusive price fixing, think of a "drug cartel." If your definition of "Cartel" necessarily includes collusion-based price fixing, you might prefer to substitute "Oligopoly" or simply "Group of people who profit by keeping secrets.")

(The Cartel-Coded chips should not be confused with the Home Again brand chips that are also popular in the U.S., or the AVID "Eurochip", or the "Foreign" ISO 11784/11785 chips that have been introduced on a limited basis. These are all examples of Open Microchip Technology chips, which require no secrets to build a scanner for. The ISO 11784/11785 chips have been problematic in the U.S. for several reasons, and some may have been "jumping the gun" in introducing them, but I would submit that these are not defective by design. With these, no Cartel secrets are needed to read the code number on a found pet.)

The manufacturers of the "Encrypted Chip" may have given lots of free scanners
to selected qualified organizations and shelters, but this doesn't change the
fact that the chips are hard to read by design. Anyway, such give-aways are not
works of charity, but rather, market manipulation which HIDES the fact that the
chips are hard to read by design. They are a big part of the means by which an
objectively unsuitable pet identification product has been successfully sold to
the public.

So the system is legal to sell as a pet recovery tool, and the Cartel has the
right to keep its secrets secret. But there are things the pet community and
APHIS can do to address the situation.

First of all, realize that while having an eventual single international ID
standard may or may not be a goal worth striving for, meeting the Open Microchip
Technology directive can be achieved independently of this goal. Meeting the
directive only requires that all chip types in current use or still implanted in
living pets be decodable using publicly available information, so that anybody
who wants to build a universal scanner can do so. Chip types other than the
"encrypted microchips" meet this criterion by design. As an example, I used
publicly available specs to give my Max Microchip project the ability to read
several nonencrypted types, and you can build my scanner without even using a
soldering iron. (As an experimenter's project, naturally its detection range is
"hobbyist grade" rather that "shelter grade".)
(I probably shouldn't have said "naturally" here. A little more involved experimenter's project made with a few parts you can't get at the Radio Shack might "naturally" make a fine shelter-grade scanner.)

But I also gave my Max Microchip scanner the ability to read the "Encrypted"
microchips using publicly available specs. How do you think I did that? The
"Encrypted Chip" makers didn't publish their secret method for converting the
chip's transmissions to a code number, so I published my own method and
standard, and used that. So the Max Microchip doesn't give the same code that
appeared on the chip's original label, as a Cartel scanner would, when it scans
an "Encrypted" microchip. Instead it gives a different 17-character code, made
according to my method which I have named "rec.pets-2005a." That may seem a
disadvantage. Cartel supporters might claim that my scanner is silly, and that a
found stray pet's proper identification code is the code that a Cartel scanner
would give, as this is the code that came printed on the label that came with
the microchip, and therefore is the code on file at the registry database. They
would have you believe that since countless pet owners and vets have bought into
the concept that the Cartel's secret algorithm's result is the pet's true
identifying characteristic, it must be so. I say that's rubbish. Only the chip's
actual transmitted waveform or a coded representation thereof made according to
a published Open Standard should properly be considered the pet's identifying
characteristic. (I mention "actual waveform" only because it would indeed be
possible for a pet registry to accept e-mailed .WAV files containing the actual
waveforms taken from found pets made by a device such as my Max Microchip. That
would be a more basic form of the pet's identifying characteristic than any code
number, but not very practical to use.)

In order for pet registry operators, with their big databases of label codes of
registered pets, to accept found pet reports by an Open standard such as
rec.pets-2005a, they would need a method of translating pet rescuers' Open
Microchip Technology Codes to Cartel codes. But I have given them such a method,
and none have complained about having to perform this extra step. (Full details
of the Translator Machine are on my web site.) They are, after all, in business
for the purpose of returning lost pets.
(Additionally, AVID and all the Cartel members have the ability to provide translator machines and translation services over the web if they want to. AVID's own pet registry is at a slight advantage here over the other registries, but that can't be helped.)

Because an "encrypted microchip" can be read on an Open Microchip Technology
scanner such as the Max Microchip to give an Open Standard code that uniquely
identifies it just as well its Cartel Code uniquely identifies it, one might
observe that the chip itself isn't really defective at all. Suppose you were to
make a new label for your chipped pet, and print on it its rec.pets-2005a
17-character code. Suppose also that your pet registry would register this code.
The pet finder could successfully report your pet without having a Cartel
scanner or any secrets, and the registry wouldn't need to use its Translator
Machine. The original label, with its hard-to-decode code number, is the
defective part of the whole pet-recovery system. If the same chips had come with
labels printed with Open Standard easy-to-get code numbers, there would be no
defect.
(The point of this example is to show that the label is the defective part and not the implanted chip itself, which is a good thing. I don't suggest that in practice, registries need to put rec.pets-2005a codes into their databases. Just having a Translator Machine allows the registry operator to make up for the defective database that results from the defective labels.)

When I realized my Max Microchip scanner project would not be able to give the
Label codes, I tried to think of some analogies representing the current
practice of microchipping pets in the U.S. Here's one of them. Suppose you've
just moved into a new town, and one day your neighbor discovers a lost French
Poodle and a Dachshund at his front door. He prints up some flyers to post
around the neighborhood. They say, "Found- One Siamese Cat and one Green
Parakeet." You ask what's going on, and he says, "In this town, we use a secret
code, non-published of course, for reporting the identifying characteristics of
stray animals. Lots of vets and pet owners support this. What do you want me to
do, come right out and give their real breeds? They might do silly things like
that where you come from, but this is the way we do it here. In fact, that
reminds me. I'm going to call the local animal control department. They use the
code of course, and they do a good job. These fine dogs likely have already been
reported lost, and they'll probably be going home quite soon, thanks to the
code. Our system is not broken. We have a few busybodies who want to scrap it,
but it works. Only problem is, there are some people who don't love animals
enough to buy the secret decoder ring. Once again, busybodies and malcontents."
If this happened to you, you would be an Open Standards stranger in Cartel Code
land.

If APHIS has been charged by Congress with implementing a system of Open
Microchip Technology, here's MY petition on what it should do:

(I really should have numbered my petition paragraphs. Here's Number 1:)
- Realize that the eventual selection of any official microchip standard is a
completely separate issue from meeting the Open Microchip Technology directive.

(Number 2:)
- Make a decision on what "Open Microchip Technology" means. Some people are
confused on this issue, as evidenced by the bottom of Page 13 of
APHIS-2006-0012-0011.1.pdf. Does "Open" mean "Anybody who wants to can build a
scanner" or "Anybody who is a member of a Cartel of secrets can build a scanner"?
(The APHIS-2006-0012-0011.1.pdf file from regulations.gov is comment number 11. It purports to come from AVID Identification Systems Inc., the maker of the so-called "encrypted" chips.)

(Number 3:)
- Realize that there are (at least) two completely different meanings for
"encryption" with regards to pet ID chips. One is Obfuscation encryption, the
use of secrets to prevent people from building scanners to read the chip's
original label code. This is what we have in the current crop of "encrypted
microchips. The other meaning of "encryption" is, the use of cryptographic
techniques to prevent counterfeiting by letting the chip prove it is genuine.
Plans for new ISO chips that have this capability are discussed on Exhibit F,
Page 37, of APHIS-2006-0012-0011.1.pdf. The sentence right above the outlined
one on this page makes it clear that no compatibility break is intended to be
made, meaning the new chips will still be just as easily readable with current
ISO compatible scanners such as my Max Microchip. So the terms "encryption
techniques" and "secret keys" refer to added ways by which a new scanner could
authenticate that the chip is genuine, not to taking away the scanner builder's
ability to use basic public techniques to read its code number on face-value. I
would expect the new chips would contain some secret information that they never
actually transmit, but instead only answer cryptographic questions about to
prove they have the secrets. I expect a good cryptographer could design the
system so that the scanner can do this without having secret information itself,
so even an authenticating scanner could be Open Microchip Technology. They're
certainly not talking about using encryption to prevent scanner builders from
getting a code number from these new "fully compatible with existing standards"
chips. In contrast, I don't see any counterfeiting prevention features in the
current "encrypted microchips." In fact, every time you use my Translator
Machine, you're "counterfeiting" a chip. They don't seem to have any
authenticating secrets they don't blab to the whole world when activated. That's
the only way I could build a Translator without knowing the secret code; it just
implements the rec.pets-2005a standard backwards to feed a signal into a Cartel
scanner containing the Secrets. I mention all this because from reading pages 7
and 13 of APHIS-2006-0012-0011.1.pdf you might get the idea that the planned
future ISO chips will have encryption similar to the way "current American
standard" chips have encryption. Uh, no.
(Page 8 of Comment number 161 has a line in it that says "The advanced transponder standard ISO 14223 will NOT include encryption." This seems to cast doubt on of the accuracy of the Article in AVID's Exhibit F. I stand by my analysis of what the article's writer says is planned for future ISO chips. Whether what's described in the article will eventually be implemented remains to be seen. It could happen. In any case, no credible evidence for serious consideration of Obfuscation encryption in ISO chips has been presented to me.)

(Number 4:)
- Ask the organizations invoked on page 2 of APHIS-2006-0012-0011.1.pdf as
supposedly being responsible in 1996 for setting the "standard for microchips in
the U.S." if any of them ever supported Obfuscation encryption as it is
currently used.
(It sure looked to me like AVID was claiming that it was through the endorsement of this long list of organizations, which includes the AKC and AVMA and others, that the US got its current "standard" under which the AVID encrypted product is one of the types of pet microchips that are approved and standardized. So is it unreasonable to suggest these groups should all be asked if they really endorsed and approved of the use of Obfuscation encryption? All the groups I can find a public position from seem to be against it now. Did they change their minds at some point? The APHIS should be able to track down the discrepancy.)

(And why should it matter what happened in 1996? If the listed groups and associations agreed to include the Cartel Coded microchip as part of the "American Microchip Standard" because they were deceived regarding what kind of encryption it has, that would mean AVID's product has been part of the Standard for ten years due to a kind of false advertising. Does anybody care about that? Maybe, maybe not.)

(Number 5:)
- Inquire for further explanation regarding the two proposals of pages 10 and 11
of APHIS-2006-0012-0011.1.pdf. Proposal 1b. looks kind of promising, but
requires clarification. Are they offering to publish the secrets so I and other
scanner builders can add decryption capability? Or are they simply proposing
that non-cartel members, and anyone who doesn't have the secrets for reading the
"existing infrastructure", be prohibited from building scanners? If prohibiting
things by regulation is on the agenda, certainly banning implanting of chips
whose decoding method is secret would be a more appropriate action if the Agency
has been tasked with implementing Open Microchip Technology. Proposal 2 is
bizarre; 125 kHz is only a frequency, not a protocol. ISO compliant chips
typically can be read fine at 125 kHz, even with crude equipment.

(Number 6:)
- Affirm that as long as microchips of any class originally marketed as a pet
recovery product exist implanted in living pets, and as long as the algorithm
for converting the signal transmissions of these chips to their original label
codes is kept secret from the pet rescuer community, these chips must be
considered not "Encrypted Chips" but rather, "Chips with an original defect in
labeling."

(Number 7:)
- Publish on the APHIS web an Open Standard for reading the defectively labeled
chips. You can copy my rec.pets-2005a, free and available now, or write your
own, or maybe somebody else has written one. It doesn't have to be mine; as long
as it's an Open Standard, the Max Microchip project and other Open scanners can
be altered to accommodate it.

(Number 8:)
- Given that we're basically talking about publishing on an FDA web-site a
work-around to an existing defective technology, I would suggest that no
additional Congressional authority would be required to do this, even without
pre-existence of the Open Microchip Technology directive. This shouldn't be
controversial, like mandating a particular type of microchip to use.
(I should have said USDA instead of FDA, right? I might have added an analogy. If the USDA knew of a specific model of tractor that was defective, would it need special authorization to publish a proceedure to modify it to keep it from exploding?)

(Number 9:)
- Of course, if someone who knows the secret algorithm decides to publish it,
that would be great. It would mean those labels are NOT DEFECTIVE ANYMORE, and
that would be a good thing. Then all our pets' chips would be Open Microchip
Technology chips.

(Number 10:)
- I would suggest that in the event that the Cartel members decide to make
universal decrypting scanners available in the U.S., while keeping the secret
algorithm secret, proper regard to the Open Microchip Technology directive would
require that the APHIS offer no material support for such a plan. Such scanners
would still be Closed Microchip Technology Scanners. Closed Microchip Technology
scanners are market and mind-share competitors with Open Microchip Technology
scanners, and they don't compete fairly.
(And, they also act to perpetuate acceptance of the obfuscation-encoded chips themselves by continuing to cover up their defects.)

(Indeed, Comment 151 purportedly from Digital Angel Corp. promises just such a product for 2007. Certainly many will find this useful, but it illustrates again how the Cartel dictates when and under what conditions scanners for the Obfuscation Encrypted chip will be available. Interestingly enough, although apparently a member of the Cartel, Digital Angel doesn't make Obfuscation Encrypted chips itself, and even expresses a view in its Comment that encryption "is not helpful".)

(And lately I've seen some things on the web to indicate that the European company Datamars may now be a member of the Cartel, and may be providing similar products even sooner. If true, the same argument applies of course. And if true, it is still unclear whether Datamars gained entry to the Cartel through a subsidiary's court action or by being good hackers.)

(As a side note, if you discount this one rather extreme part of my petition and consider it severable, there's very little in my petition that conflicts with the diverse position papers and suggestions of the readallchips.com (now moved to readallchips.org???) Coalition's Comment #166, the amacausa.org Council's Comments #142 and 162, the American Kennel Club's Comment #155, and a lot of others that made Comments. The AKC position seems compatible with mine even with this, my most radical suggestion, intact. If you look at the bottom of page 20 of their Comment number 155, it calls for a scanner specification which supports all "unencrypted chips which are, or have been, in widespread use in the United States". I would only want to add rec.pets.2005a support to that.)

(If all this Cartel, Coalition, Club, and Council stuff has you confused, just wait. I'm thinking about forming a Cooperative Conspiratorial Confederacy for Open Microchip Technology supporters. That means, anybody who thinks a pet rescuer shouldn't need Cartel secrets to read a found pet's code number can join us. The old readallchips Coalition never specifically demanded this; their call for universal scanners, as written, would seem to be fully satisified by the availability of new Cartel scanners with added ISO support. As for the new amacausa.org Council, although it has at least one political/ideological test for prospective members on its application form, supporting this basic tenet of Open readability for pet rescuers is not a requirement. And its original October 12, 2006 membership list includes AVID and EID/Trovan. That's half the Cartel signed up already.)

 (Number 11:)
- Put some standard in place for what constitutes a shelter-grade scanner. Here
are some of my ideas on this. Suppose there are two scanners hanging on the wall
at the animal shelter. Scanner A has a read range of 3 inches, and a reading
time of 0.2 seconds. Scanner B has a read range of 2.5 inches, and a reading
time of 0.5 seconds. Suppose your lost pet is about to get scanned one last
time, and furthermore suppose his chip has slipped a little bit, so it's not
where it's expected to be. There is a very real chance that the coil will not be
held close enough for a long enough time for a reading to be made. Which scanner
would you prefer to be used on your pet? How about Scanner B, the weaker, slower
one? Which would you consider a better example of a shelter-grade scanner? But
let me tell you a little more about Scanner B. Scanner B has an extra audible
signal and a light that flashes when it hears any kind of signal at all,
regardless of whether decoding it is possible. It's designer knew that there
might be chip types he had never heard of or that are too obscure to support, or
that there might be cases where a pet may have been injected with two chips
which will effectively jam each other unless you hold the pickup coil just right
to null out one of them, or use a pinpointing coil. Also, sometimes if you hold
a chip in the far-out weak area of the excitation field, it may put out a faint
chatter signal, detectable but unintelligible. Suppose scanner B's "extended
detect" capabilities work at 4 inch range and require the faint signal to be
present for only 0.1 second or less. Its code reading time and range are poorer
than that of Scanner A because its designer knew the extended detect range was
more important to concentrate his efforts on. If the operator hears or sees this
extended detect response, of course he will use it to zero in on the location of
the chip until a reading can be made. Now which scanner is the shelter-grade one
you'd want to have used on your pet? (All the specific numbers in this example
are made up.) There was a story in the press some time ago about a lady who lost
her beloved pet because her pet had a microchip of a type the scanner couldn't
read. I say, if the scanner had been a true Shelter-Grade scanner, it would have
beeped regardless of whether it knew how to extract a code number. A scanner
with a good extended detect response like this can stand to have a little longer
read time, which is lucky for anyone trying to make a shelter-grade
rec.pets-2005a scanner. With rec.pets-2005a, only matching of repetitions of the
message is available for error checking, so read times may indeed be a half
second or so. Performing public-key authentication, when this becomes available
with newer chip types, may take even longer, but that's OK too.
(I might add an opinion that in practice, the amount of read range deficit that would come with adding such an extended detect feature is probably not going to be a half inch as in my numeric example. It's more likely going to be too small to measure.)

(Another advantage of such a feature is that it makes time-to-decode less important so that it becomes prudent to listen for and verify an extra repetition of the chip's response message. The Writer of Comment 165 apparently has discovered that the design of the ISO type pet chips has a flaw such that a single bit reading error at the right place in the transmitted message from these chips may not be detected by the standard's error detection method and will result in an erroneous reading. A little extra time to check for a match between repetitions can be a work-around for this.)

(For Chip Makers, the work-around for this apparent flaw is to not make any chips with a code number that makes them susceptible. The Comment seems to suggest that one in every 256 would have a susceptible number, but I'm thinking it might really be more like 1 in a million. In practice such erroneous readings may prove uncommon even for chips with susceptible numbers, and typically will show a bogus-looking value for the Country/Manufacturer code.)

(Number 12:)
- Publish some kind of warning on the hazards of Double Chipping. The writer of
APHIS-2006-0012-0011.1.pdf page 9 paragraph g. seems to think this is a good and
reasonable thing to do in some cases. But in my limited testing, I've found that
a standard Avid scanner, which can normally detect an "encrypted chip" at over
two inches range, can't detect it at a half inch when an ISO type chip is placed
alongside it or in front of it or sometimes even behind it a little bit.
Remember, there's really no such thing as a 125 kHz chip or 134 kHz chip; they
all use the frequency of the excitation field. They can jam each other's
signals. A lot of testing could be done on this issue, with lots of different
scanner and chip types, but it's pretty easy to see the problem is real. For one
chip to jam another's signal, it doesn't need to be immediately adjacent; it
only needs to be, roughly speaking, equally close to the detector coil.
(Actually several Comments suggested double chipping in some cases. On reflection, I would approve of placing two chips if necessary with some separation. An appropriate warning on the Hazards of Double Chipping might simply say, don't add an ISO chip with an existing non-ISO chip just to be the first on the block to have one, and if you must double chip, such as in a pet that has an ISO chip in an area without full ISO implementation, separation between the two chips is good.)

(Number 13:)
- Consequently, realize that the only way to make sure that pets that have been
imperiled by implantation of multiple chips are safe requires the current
infrastructure of shelter scanners to be replaced anyway, with true
Shelter-Grade readers as I've described above. You can't do this right away;
they don't exist yet, as far as I know. A multi-standard reader that has some
chance of getting a reading on EACH of the pet's two chips in spite of the
jamming effect is better than an equivalent reader that only has a chance of
picking up one of them, but I would consider the addition of the extended detect
feature I've described above essential. How urgent this is may depend on whether
YOUR pet got double chipped.
("Imperiled" is too strong a word here. Maybe I should have just said that gratuitous double chipping is a theoretical hazard, and from the perspective of a scanner designer, there are ways to design a scanner to completely avoid it, at least in the sense of, two chips heard together won't cause an extended-detect scanner to be SILENT.)

(Number 14:)
- Optionally, the APHIS might wish to lobby for a new world-wide pet ID chip and
Shelter-Grade scanner standard based on the current ISO standard with changes
such as: 1. Decent punctuation in the ISO code number. 2. Guaranteed performance
of chips under both 125 and 134 kHz excitation. 3. An optional new Public-Key
authentication method. 4. Elimination of the requirement for scanners to support
the silly ISO "half-duplex" mode in pet applications. 5. Required scanner
support for all the various types of unencrypted chips. And, 6. Required scanner
support for obfuscation-encrypted chips via rec.pets-2005a or a similar method.
I'd like to see it as a true free open standard, not like the ISO standard I had
to pay Bucks to download a copy of. U.S. shelter scanners could then be replaced
with true shelter-grade scanners that have the ability to read the ISO-like
protocol transmitted by these new chips, while still using only 125 kHz
excitation to maintain top performance reading the common U.S. chips. Current
ISO standard chips might read quite well with these new scanners, but chips
designed and tested to read at both frequencies might prove popular in any
country where people might consider visiting the U.S. (Such as Canada!) Then
after some years, it might be considered quite prudent for a U.S. pet owner who
plans to travel the world with Fido, to choose the modified ISO chip type, by
then universally readable in the U.S., and more readable world-wide than non-ISO
types.
(For number 5, I should have said, "all the common types of unencrypted pet chips." Meaning, there would be no support for the half-duplex ISO chips used in livestock tracking. Support for these would necessarily reduce efficiency in reading the types used in pets.)

Thank you for your attention,
Andy Kluck

(Cartel scanners have helped return thousands of pets to their owners by using the secret decryption algorithm. The same job could have been done by Open Microchip Technology scanners using a concept like my suggested work-around, with Cartel scanners necessary only in Registry offices' translator machines. Cartel scanners have a value advantage over my work-around, in that the code string to be transmitted to the registry is shorter, and the registry doesn't have an extra step to perform. But Cartel scanners have an additional cost too, in that they cover up the defects of the AVID "encrypted" chip. It's an unmeasurable, but large cost; the widespread distribution of these scanners as "infrastructure" has kept people from figuring out that the AVID product is defective for over 10 years, with millions implanted. This won't make sense to you if you think the right way to build a pet ID/recovery product is to use secret codes that prevent the pet finder from reading it, but I say this is a real hidden cost of the Cartel scanners. This hidden cost also means no animal shelter or humane society REALLY got one for free. They weren't just scanners whose distribution was subsidized from chip sales, which would be good business and quite admirable; they were scanners that hide the defects of the chips, or in my alternative view, their original labels.)

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