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DULT Threat Model
draft-ietf-dult-threat-model-04

Document Type Active Internet-Draft (dult WG)
Authors Maggie Delano , Jessie Lowell , Shailesh Prabhu
Last updated 2026-02-26
Replaces draft-delano-dult-threat-model
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draft-ietf-dult-threat-model-04
Detecting Unwanted Location Trackers                           M. Delano
Internet-Draft                                        Swarthmore College
Intended status: Informational                                 J. Lowell
Expires: 30 August 2026        National Network to End Domestic Violence
                                                               S. Prabhu
                                                                   Nokia
                                                        26 February 2026

                           DULT Threat Model
                    draft-ietf-dult-threat-model-04

Abstract

   Lightweight location-tracking tags are in wide use to allow users to
   locate items.  These tags function as a component of a crowdsourced
   network in which devices belonging to other network users (e.g.,
   phones) report which tags they see and their location, thus allowing
   the owner(s) of the tag to determine where their tag was most
   recently seen.  While there are many legitimate uses of these tags,
   they are also susceptible to misuse for the purpose of stalking and
   abuse.  A protocol that allows others to detect unwanted tracking
   must incorporate an understanding of the unwanted tracking landscape
   today.  This document provides a threat analysis for this purpose,
   including a taxonomy of unwanted tracking and potential attacks
   against Detection of Unwanted Location Tracking (DULT) protocols.
   The document defines what is in and out of scope for the unwanted
   tracking protocols, and provides design requirements, constraints,
   and considerations for implementation of protocols to detect unwanted
   tracking.

About This Document

   This note is to be removed before publishing as an RFC.

   The latest revision of this draft can be found at https://ietf-wg-
   dult.github.io/threat-model/draft-ietf-dult-threat-model.html.
   Status information for this document may be found at
   https://datatracker.ietf.org/doc/draft-ietf-dult-threat-model/.

   Discussion of this document takes place on the Detecting Unwanted
   Location Trackers Working Group mailing list (mailto:unwanted-
   trackers@ietf.org), which is archived at
   https://mailarchive.ietf.org/arch/browse/unwanted-trackers/.
   Subscribe at https://www.ietf.org/mailman/listinfo/unwanted-
   trackers/.

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   Source for this draft and an issue tracker can be found at
   https://github.com/ietf-wg-dult/threat-model.

Status of This Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
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   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   This Internet-Draft will expire on 30 August 2026.

Copyright Notice

   Copyright (c) 2026 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents (https://trustee.ietf.org/
   license-info) in effect on the date of publication of this document.
   Please review these documents carefully, as they describe your rights
   and restrictions with respect to this document.  Code Components
   extracted from this document must include Revised BSD License text as
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   provided without warranty as described in the Revised BSD License.

Table of Contents

   1.  Introduction  . . . . . . . . . . . . . . . . . . . . . . . .   4
     1.1.  Applicability . . . . . . . . . . . . . . . . . . . . . .   5
   2.  Conventions and Definitions . . . . . . . . . . . . . . . . .   6
     2.1.  Conventions . . . . . . . . . . . . . . . . . . . . . . .   6
     2.2.  Definitions . . . . . . . . . . . . . . . . . . . . . . .   6
   3.  Security Considerations . . . . . . . . . . . . . . . . . . .   9
     3.1.  Security Considerations Unique To Unwanted Location
           Tracking  . . . . . . . . . . . . . . . . . . . . . . . .   9
     3.2.  Balancing Privacy and Security  . . . . . . . . . . . . .   9
       3.2.1.  Security against Unwanted Tracking for potential
               Targets . . . . . . . . . . . . . . . . . . . . . . .  10

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       3.2.2.  Privacy for potential Targets against the use of
               security measures for further surveillance  . . . . .  10
       3.2.3.  Privacy for unassociated Tag Owners . . . . . . . . .  10
     3.3.  Taxonomy of Unwanted Tracking . . . . . . . . . . . . . .  11
       3.3.1.  Example scenarios with analyses . . . . . . . . . . .  14
       3.3.2.  Bluetooth vs. other technologies  . . . . . . . . . .  22
     3.4.  Possible Attacks on the DULT Protocol . . . . . . . . . .  22
       3.4.1.  Threat Prioritization Framework for DULT Threat
               Model . . . . . . . . . . . . . . . . . . . . . . . .  22
       3.4.2.  Threat Matrix . . . . . . . . . . . . . . . . . . . .  23
       3.4.3.  Deploying Multiple Tags (Finding) . . . . . . . . . .  25
       3.4.4.  Remote Advertisement Monitoring (Accessory,
               Network)  . . . . . . . . . . . . . . . . . . . . . .  26
       3.4.5.  Physically Modifying Tags (Accessory) . . . . . . . .  27
       3.4.6.  Accessory Firmware Modifications (Accessory)  . . . .  27
       3.4.7.  Attacker Accessory Disablement (Accessory,
               Finding)  . . . . . . . . . . . . . . . . . . . . . .  28
       3.4.8.  Tracking Using Target's Own Tag (Network) . . . . . .  28
       3.4.9.  Disabling Target Tag Detection (Network)  . . . . . .  29
       3.4.10. Disabling Target Tag (Accessory, Network) . . . . . .  29
       3.4.11. Impersonation Attack (Tag; Accessory, Finding,
               Network)  . . . . . . . . . . . . . . . . . . . . . .  29
       3.4.12. Impersonation Attack (Device) . . . . . . . . . . . .  30
       3.4.13. Replay Attack (Accessory, Network)  . . . . . . . . .  31
       3.4.14. Heterogeneous Tag Networks (Accessory, Finding,
               Network)  . . . . . . . . . . . . . . . . . . . . . .  32
       3.4.15. Deploying GPS Tracker (Accessory) . . . . . . . . . .  32
     3.5.  Scope and Priorities for the DULT WG  . . . . . . . . . .  33
       3.5.1.  Technologies  . . . . . . . . . . . . . . . . . . . .  33
       3.5.2.  Attacker Profiles . . . . . . . . . . . . . . . . . .  33
       3.5.3.  Target Profiles . . . . . . . . . . . . . . . . . . .  33
       3.5.4.  Priorities  . . . . . . . . . . . . . . . . . . . . .  33
   4.  Design Considerations . . . . . . . . . . . . . . . . . . . .  34
     4.1.  Limitations of existing approaches to detecting and
           preventing Unwanted Tracking  . . . . . . . . . . . . . .  34
       4.1.1.  Spotty Implementation . . . . . . . . . . . . . . . .  35
       4.1.2.  Lack of customizability . . . . . . . . . . . . . . .  35
       4.1.3.  Difficulty finding and disabling tags . . . . . . . .  36
       4.1.4.  Nonconformant Tags  . . . . . . . . . . . . . . . . .  36
       4.1.5.  Activities Logs . . . . . . . . . . . . . . . . . . .  37
       4.1.6.  Anti-theft mode . . . . . . . . . . . . . . . . . . .  37
     4.2.  Design Requirements . . . . . . . . . . . . . . . . . . .  38
       4.2.1.  Detecting Unwanted Location Tracking  . . . . . . . .  38
       4.2.2.  Finding Tracking Tags . . . . . . . . . . . . . . . .  42
       4.2.3.  Disabling Tracking Tags . . . . . . . . . . . . . . .  42
       4.2.4.  Notification Management for Trusted Accessories . . .  43
     4.3.  Design Constraints  . . . . . . . . . . . . . . . . . . .  44
       4.3.1.  Bluetooth constraints . . . . . . . . . . . . . . . .  44

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       4.3.2.  Power constraints . . . . . . . . . . . . . . . . . .  45
       4.3.3.  Device constraints  . . . . . . . . . . . . . . . . .  46
     4.4.  Priorities for the DULT WG  . . . . . . . . . . . . . . .  47
   5.  IANA Considerations . . . . . . . . . . . . . . . . . . . . .  48
   6.  Normative References  . . . . . . . . . . . . . . . . . . . .  48
   Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . .  49
   Authors' Addresses  . . . . . . . . . . . . . . . . . . . . . . .  49

1.  Introduction

   Location-tracking tags allow users to locate items.  These tags
   function as a component of a crowdsourced network in which devices
   belonging to other network users (e.g. phones) report on the location
   of tags they have seen.  At a high level, this works as follows:

   *  Tags ("Accessories") transmit a Location-enabled Advertisement
      Payload containing Accessory-specific information.  The Payload
      indicates whether the Accessory is separated from its Owner(s) and
      thus potentially lost.

   *  Devices belonging to other users ("Non-Owner Devices") observe
      those Payloads and if the Payload is in a separated mode, report
      its location to a Crowdsourced Network.

   *  The Owner(s) queries the Crowdsourced Network for the location of
      their Accessory.

   A naive implementation of this design exposes both a Tag's user and
   anyone who might be targeted for location tracking by a Tag's user,
   to considerable privacy risk.  In particular:

   *  If Accessories simply have a fixed identifier that is reported
      back to the Crowdsourced Network, then the central server is able
      to track any Accessory without the user's assistance.

   *  Any Attacker who can guess a Tag ID can query the Crowdsourced
      Network for its location.

   *  Any Attacker who can observe a Tag ID at one time can query the
      Crowdsourced Network for its location at another time.

   *  An Attacker can surreptitiously plant an Accessory on a Target and
      thus track them by tracking their "own" Accessory.

   *  Attackers could launch Denial-of-Service (DoS) attacks by flooding
      the Crowdsourced Network with spoofed Tag reports, disrupting real
      updates and overwhelming the Network.

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   *  Frequent co-location of multiple Tags enables the Crowdsourced
      Network or a passive observer to infer social relationships,
      routines, or group behaviors, compromising user privacy without
      consent.

   Detecting Unwanted Tracking is currently left to individual Tag
   manufacturers and Platforms on Non-Owner Devices.  Each manufacturer
   and Platform has different implementations to prevent Unwanted
   Tracking, which may or may not be compatible with other manufacturers
   or Platforms.  The goal of the IETF Detecting Unwanted Location
   Tracking (DULT) working group is to standardize a protocol between
   Location-tracking Tags, Non-Owner Devices, and Crowdsourced Networks.

   In order to standardize a protocol for Detecting Unwanted Location
   Tracking, thus minimizing the privacy risks described above, it is
   necessary to analyze and be able to model different privacy threats.
   This document includes: 1) a taxonomy of Unwanted Tracking, 2)
   methods Attackers could use to circumvent the DULT Protocol, and 3)
   design considerations for implementing the DULT protocol.  The
   taxonomy of Unwanted Tracking uses a flexible framework to provide
   analysis and modeling of different threat actors, as well as models
   of potential Targets based on their threat context.  It defines how
   these Attacker and Target persona models can be combined into threat
   models.  The section on methods to circumvent the DULT protocol
   includes a threat matrix and description of several different
   possible attack vectors.  Finally, the design considerations section
   focuses on specific requirements and constraints for successfully
   detecting Unwanted Tracking, alerting users, and providing guidance
   on disabling Tags (if desired).  This threat model document is
   intended to inform the work of the implementation of the DULT
   Protocol as described in [I-D.draft-ietf-dult-accessory-protocol] and
   [I-D.draft-ietf-dult-finding].  The DULT Protocol is based on an
   earlier Internet Draft; see
   [I-D.draft-ledvina-apple-google-unwanted-trackers].

1.1.  Applicability

   While there are many types of technology that can be used for
   Location Tracking, it is infeasible to attempt to describe a threat
   analysis for each possible technology in this document.  The threat
   model described here is likely not applicable to the following areas:
   app-based technologies such as parental monitoring apps that do not
   use Location-tracking Accessories, Internet of Things (IoT) devices
   that are easily discoverable, connected cars, or user accounts for
   cloud services or social media.  A notable exception to this is GPS
   trackers; see Section 3.3.2 for relevant information and
   recommendations.

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   This threat model is also more likely to be applicable in regions
   where the use of Location-tracking Tags is more prevalent.  While
   Location-tracking Tags have existed for over a decade, they became
   especially widely-used in the Global North in the last several years
   as Crowdsourced Networks were deployed by major smart phone
   manufacturers.  However, due to their reliance on a high density of
   Non-Owner Devices for the network to be effective and the relative
   cost of Location-tracking Tags, Location-tracking Tag use in the
   Global South is typically limited to affluent communities.  If the
   cost of Non-Owner Devices and Location-tracking Tags decrease, an
   uptick of could also occur in contexts where it is currently
   infeasible.  This threat-model does still attempt to consider
   possible regional differences in Location-tracking Tag use (such as
   differences between rural and urban use), and also the sometimes
   limited resources that may be available to Targets of Unwanted
   Tracking.

2.  Conventions and Definitions

2.1.  Conventions

   The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT",
   "SHOULD", "SHOULD NOT", "RECOMMENDED", "NOT RECOMMENDED", "MAY", and
   "OPTIONAL" in this document are to be interpreted as described in
   BCP 14 [RFC2119] [RFC8174] when, and only when, they appear in all
   capitals, as shown here.

2.2.  Definitions

   *Accessory*:  any product intended to interface with a Platform to
      connect to a Crowdsourced Network through the means described in
      these documents.

   *Active Scanning*:  method(s) of Unwanted Tracking detection that
      involves a user initiated scan for nearby Accessories.  Contrast
      with Passive Scanning.

   *Attacker*:  any individual, group, or organization that is
      attempting to engage in Unwanted Tracking and/or circumvention of
      the DULT Protocol.

   *Crowdsourced Network*:  a service that Platforms communicate with to
      share and retrieve location information of Accessories.

   *Disablement*:  the process of preventing a specific Location-

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      tracking Accessory from communicating with the Crowdsourced
      Network.  This could be through physical means (e.g. removing the
      battery) or via a command sent by a Platform to an Accessory (e.g.
      Remote Disablement).

   *Disablement Instructions*:  steps Non-Owner Device users can take to
      disable a Location-tracking Accessory suspected of Unwanted
      Tracking.

   *Device*:  Hardware that includes software for a Platform and that
      can connect to Accessories and one or more Crowdsourced Networks.
      Examples of Devices are phones, tablets, laptops, etc.

   *Detecting Unwanted Location Tracking (DULT) Protocol*  the protocol
      under development by the IETF DULT working Group to prevent
      Unwanted Tracking.  This includes protocols for Accessories and
      the crowd sourced network, along with algorithms for detecting
      Unwanted Tracking.

   *Easily Discoverable*:  an Accessory that is larger than 30 cm in at
      least one dimension, larger than 18 cm x 13 cm in two of its
      dimensions, and/or larger than 250 cm^3 in three-dimensional
      space.

   *Location-enabled Advertisement Payload*:  the Bluetooth (BT)
      advertisement payload that is advertised when an Accessory has
      recently, is currently, or will in the future provide location
      updates to its Owner.

   *Location-enabled State*:  the state an Accessory is in where its
      location can be remotely viewed by its Owner.

   *Location-tracking Accessory*:  any Accessory that has location-
      tracking capabilities, including, but not limited to, crowdsourced
      location, GPS/GNSS location, WiFi location, cell location, etc.,
      and provides the location information back to an Owner Device via
      a Crowdsourced Network using the internet, cellular connection,
      etc.  Location-tracking Accessories that are Easily Discoverable
      MUST adhere to the DULT Protocol.  Location-tracking Accessories
      may also be referred to as Location-tracking Tags.

   *Location-tracking Tag*:  a term that may be used interchangeably
      with Location-tracking Accessory.

   *Non-Owner Device*:  a Device that may connect to an Accessory but is
      not an Owner Device of that Accessory.

   *Owner*:  an individual that is in active control of and the primary

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      user of an Owner Device.  An Owner may be associated with one or
      more Accessories and/or Devices.

   *Owner Device*:  a Device that is associated with the Accessory and
      can retrieve the Accessory's location by querying the Crowdsourced
      Network.

   *(Obfuscated) Owner Information*:  (obfuscated) contact information
      for an Accessory Owner.  When an Accessory is marked as lost, this
      should include a phone number and/or email address.  Otherwise,
      the information should be obfuscated to ensure privacy of Owners
      in cases where Accessories are falsely suspected of Unwanted
      Tracking or an Attacker attempts to determine the Owner of an
      Accessory.  The information should include no more than the last
      two digits of a phone number and/or an obfuscated email address
      with the first letter of the username and entity visible, as well
      as the entire extension (e.g., b*****@i****.com).

   *Passive Scanning*:  method(s) of Unwanted Tracking detection that
      are running in the background on all Devices and may trigger
      Unwanted Tracking Alerts.  Contrast with Active Scanning.

   *Platform*:  Operating systems that communicate with Accessories.

   *Platform-compatible Method*:  a method of communication between the
      Platform and the Accessory/Accessory manufacturers to exchange
      information, including, but not limited to, BT GATT protocol, BT
      advertisement, HTTP, etc.

   *Remote Disablement*:  the process of preventing a specific Location-
      tracking Accessory from communicating with the Crowdsourced
      Network via a command sent by a Platform.

   *Tag*:  shorthand for Location-tracking Tag; see Location-tracking
      Accessory for full definition.

   *Target*:  a individual who an Attacker is attempting to track
      without their consent.  A Target may or may not own a Location-
      tracking Accessory.

   *Unwanted (Location) Tracking (UT)*:  undesired tracking of a person,
      their property, or their belongings by a Location-tracking
      Accessory.

   *Unwanted Tracking Alert*:  an alert from a Device which notifies the

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      user of the presence of an unrecognized Accessory that may be
      traveling with them over time.  The alert allows the user to take
      various actions, including sending a command to the Accessory to
      emit a sound if the Accessory is in Bluetooth Low Energy (BLE)
      range.

   *Unwanted Tracking Detection*:  algorithms that detect the presence
      of an unknown Accessory traveling with a person over time.

3.  Security Considerations

   Incorporation of this threat analysis into the DULT Protocol does not
   introduce any security risks not already inherent in the underlying
   Location-tracking Tag protocols.

3.1.  Security Considerations Unique To Unwanted Location Tracking

   In a situation involving interpersonal control, an Attacker may be
   more likely to have access to a Target's Device or passwords.  The
   Attacker could have physical access to a mobile Device on which a
   tracking account app is installed, remote access through a web
   portal, or both.  The risk of an Attacker accessing a Target's
   tracking account remotely can be mitigated, though not eliminated,
   through support for different forms of multi-factor authentication
   (including hardware keys, e.g. Yubikeys, as well as more traditional
   methods).  While this can also be used to mitigate the risk posed by
   physical access, taking overt security measures while frequently in
   physical proximity to the Attacker may lead to the Attacker
   escalating their tactics of interpersonal control.  Risk assessments
   and the weighing of tradeoffs in such situations are often highly
   individualized.  The ability of a user to access a tracking account
   over a web portal illustrates the need to consider web app security
   as part of support for detecting Unwanted Tracking.

3.2.  Balancing Privacy and Security

   In order to avoid pitting the privacy of Tag Owners not engaged in
   Unwanted Tracking against the security/safety of Targets, the DULT
   Protocol must consider and balance the privacy and safety of
   different users of the Crowdsourced Network.  Existing attempts to
   prevent Unwanted Tracking (i.e. where an Attacker uses their own Tag
   to track a Target without their consent) have been criticized as
   potentially making it easier for an Attacker to track a Target using
   the Target's own Tag. This can occur if Tags do not rotate
   identifiers frequently enough.  However, Eldridge et al. have
   demonstrated (https://eprint.iacr.org/2023/1332.pdf) a technological
   solution that employs secret sharing and error correction coding that
   may preserve the privacy of Tag Owners without reducing the efficacy

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   of detecting Unwanted Tracking.

3.2.1.  Security against Unwanted Tracking for potential Targets

   The DULT Protocol must make it possible for potential Targets to
   discover Unwanted Tracking across Accessory hardware and Platforms
   within a reasonable amount of time.  It should aid the Target in
   determining the location and Owner of the Accessory while not
   providing a full name or contact information on demand (as the Tag
   may merely have been lost or otherwise coincidentally in proximity,
   and providing excessive information would violate the privacy of a
   non-malicious Tag Owner).  This could potentially be done with
   obfuscation, such as showing a partially redacted email address or
   phone number (see Section 4.2.1.1).

3.2.2.  Privacy for potential Targets against the use of security
        measures for further surveillance

   The DULT Protocol must consider the threat vector of an Attacker with
   access to a Target's Tag-associated account.  In one study of how
   intimate partners misuse technology Freed et al, 2018
   (https://dl.acm.org/doi/pdf/10.1145/3173574.3174241), 72% of
   survivors reported being forced or coerced to share passwords with an
   abuser. 41% reported that a cohabiting abuser "went through" their
   Device while they were not looking, allowing the abuser to obtain
   saved account passwords in many cases. 67% reported that an abuser
   was able to "hack" into their accounts remotely.  To prevent use of a
   Target's own Tag as a means of surveillance, the protocol should
   minimize information that can be accessed from a web interface
   associated with a user's Tag-linked account.

3.2.3.  Privacy for unassociated Tag Owners

   Any unassociated Tag Owner, whether an abuse/stalking survivor or
   not, could potentially be the Target of an attack leveraging the
   Target's own Tags.  Survivors and activists for women's and LGBTQIA+
   rights, and/or against intimate interpersonal violence, may face
   severe government surveillance, repression, and even imprisonment
   Amnesty International, 2025
   (https://www.amnesty.org/en/latest/news/2025/03/iran-authorities-
   target-womens-rights-activists-with-arbitrary-arrest-flogging-and-
   death-penalty/), Human Rights Watch, 2020
   (https://www.hrw.org/news/2020/03/18/kazakhstan-womens-day-activists-
   convicted), Ruiz-Navarro, 2015 (https://www.theguardian.com/global-
   development/2015/mar/18/honduras-women-gladys-lanza-feminism-human-
   rights).  Broad issues of technological privacy, including privacy
   against government and corporate surveillance, affect many
   populations, including but not limited to human rights defenders,

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   children, migrants, and LGBTQIA+ people.  Some people in these
   categories may _also_ be survivors of abuse or stalking.  The DULT
   Protocol must not eschew legitimate privacy interests of Tag Owners
   in the name of safety and security for Targets.

   The same person may be a Target of both Unwanted Tracking via an
   Attacker's Tag, and surveillance via their own Tag, either at
   different times or simultaneously.  The DULT Protocol should account
   for this scenario.

3.3.  Taxonomy of Unwanted Tracking

   To create a taxonomy of threat actors, we can borrow from Dev et
   al.’s Models of Applied Privacy (MAP) framework
   (https://dl.acm.org/doi/fullHtml/10.1145/3544548.3581484).  This
   framework is intended for organizations and includes organizational
   threats and taxonomies of potential privacy harms.  Therefore, it
   cannot be applied wholesale.  However, its flexibility, general
   approach to personas, and other elements, are applicable or can be
   modified to fit the DULT context.

   The characteristics of threat actors may be described as follows.
   This is not intended to be a full and definitive taxonomy, but an
   example of how existing persona modeling concepts can be applied and
   modified.

   *  Expertise level

      -  Expert: The Attacker works in or is actively studying computer
         science, networking, computer applications, IT, or another
         technical field.

      -  Non-expert: The Attacker does not work or study in, or is a
         novice in, a technical field.

   *  Proximity to Target

      -  High: Lives with Target or has easy physical access to Target
         and/or Target’s possessions.

      -  Medium: Has some physical access to the person and possessions
         of someone who lives with Target, such as when the Attacker and
         Target are co-parenting a child.

      -  Low: Does not live with or have physical access to Target and/
         or Target’s possessions.

   *  Access to resources

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      -  High: The Attacker has access to resources that may amplify the
         impact of other characteristics.  These could include, but are
         not limited to, funds (or control over “shared” funds), persons
         assisting them in stalking behavior, or employment that
         provides privileged access to technology or individuals’
         personal information.

      -  Low: The Attacker has access to few or no such resources.

   In addition, the Target also has characteristics which influence the
   threat analysis.  As with Attacker characteristics, these are not
   intended as a definitive taxonomy.

   *  Expertise level

      -  Expert: The Target works in or is actively studying computer
         science, networking, computer applications, IT, or another
         technical field.

      -  Non-expert: The Target does not work or study in, or is a
         novice in, a technical field.

   *  Expectation of Unwanted Tracking

      -  Suspecting: The Target has reason to believe that Unwanted
         Tracking is a likely risk.

      -  Unsuspecting: The Target has no particular reason to be
         concerned about Unwanted Tracking.

   *  Access to resources

      -  High: The Target is generally able to safely access practical
         and relevant resources.  These might include funds to pay a car
         mechanic or private investigator, law enforcement or legal
         assistance, or other resources.

      -  Low: The Target is generally unable to safely access practical
         and relevant resources.

   *  Access to technological safeguards

      -  High: The Target is able to safely use, and has access to,
         technological safeguards such as active scanning apps.

      -  Limited: The Target is able to safely use, and has access to,
         technological safeguards such as active scanning apps, but is
         unable to use their full capacity.

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      -  Low: The Target is not able to use technological safeguards
         such as active scanning apps, due to reasons of safety or
         access.

   It is also appropriate to define who is using the Location-tracking
   Tags and incorporate this into a model.  This is because if protocols
   overly deprioritize the privacy of tracking Tags’ users, an Attacker
   could use a Target’s own Tag to track them (see Section 3.2).

   *  Tracking Tag usage

      -  Attacker only: The Attacker controls one or more Location-
         tracking Tags, but the Target does not.

      -  Target only: The Target controls one or more Location-tracking
         Tags, but the Attacker does not.

      -  Attacker and Target: Both the Attacker and Target control one
         or more Location-tracking Tags.

   Any of the threat analyses above could be affected by placement of
   the Tag(s).  For instance, a Tag could be placed on a Target's
   person, or in proximity to a Target but not on their person (e.g. a
   child's backpack).

   *  Tag placement

      -  Tag on Target's person or immediate belongings: This attack
         vector allows an Attacker to track a Target in a fine-grained
         way.  It is also more likely that this attack would trigger an
         alert from the Tag.

      -  Tag(s) in proximity to Target but not on their person (e.g.
         child's backpack, car): While this is a less fine-grained
         attack, it may also be less likely to be discovered by the
         Target.  A child may not realize the significance of an alert
         or know how to check for a Tag. A parent may not think to scan
         for such a Tag, or may have more difficulty finding a Tag in a
         complex location such as a car.

      -  Tags nearby but not used for Unwanted Tracking (e.g. false
         positives by companions or on transit): While this is not an
         attack vector in its own right, repeated false positives may
         discourage a Target from treating alerts seriously.

      -  Multiple Tags using multiple types of placement: This attack
         vector may trick a Target into believing that they have fully
         addressed the attack when they have not.  It also allows for a

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         diversity of monitoring types (e.g. monitoring the Target's
         precise location, monitoring a child's routine, monitoring car
         usage).

3.3.1.  Example scenarios with analyses

   The following scenarios are composite cases based upon reports from
   the field.  They are intended to illustrate different angles of the
   problem.  They are not only technological, but meant to provide
   realistic insights into the constraints of people being targeted
   through Location-Tracking Tags.  There is no identifying information
   for any real person contained within them.  In accordance with
   research on how designers understand personas (https://dl.acm.org/
   doi/10.1145/2207676.2208573), the characters are given non-human
   names without attributes such as gender or race.

   The analysis of each scenario provides an example usage of the
   modeling framework described above.  It includes a tracking Tag usage
   element for illustrative purposes.  However, as discussed previously,
   this element becomes more or less relevant depending on protocol
   evolution.  Note that once a given Attacker persona has been modeled,
   it could be recombined with a different Target persona, or vice
   versa, to model a different scenario.  For example, a non-expert
   Target persona could be combined with both non-expert and expert
   Attacker personas.

3.3.1.1.  Scenario 1

3.3.1.1.1.  Narrative

   Mango and Avocado have two young children.  Mango, Avocado, and the
   children all use smartphones, but have no specialized technical
   knowledge.  Mango left because Avocado was abusive.  They were
   homeless for a month, and the children have been living with Avocado.
   They now have an apartment two towns away.  They do not want Avocado
   to know where it is, but they do want to see the children.  They and
   Avocado meet at a public playground.  They get there early so that
   Avocado will not see which bus route they arrived on and keep playing
   with the children on the playground until after Avocado leaves, so
   that Avocado will not see which bus route they get on.  Two days
   later, Avocado shows up at Mango’s door, pounding on the door and
   shouting.

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3.3.1.1.2.  Analysis

   In this case, the Attacker has planted a Tag on a child.  Co-
   parenting after separation is common in cases of intimate partner
   violence where the former partners have a child together.  Child
   visits can be an opportunity to introduce technology for purposes of
   stalking the Target.

   +=====================+============================================+
   | Attacker Profile    | Avocado                                    |
   +=====================+============================================+
   | Expertise Level     | Non-Expert                                 |
   +---------------------+--------------------------------------------+
   | Proximity to Target | Medium                                     |
   +---------------------+--------------------------------------------+
   | Access to Resources | Unknown, but can be presumed higher than   |
   |                     | Mango’s due to Mango’s recent homelessness |
   +---------------------+--------------------------------------------+

                                 Table 1

            +====================================+============+
            | Target Profile                     | Mango      |
            +====================================+============+
            | Expertise Level                    | Non-Expert |
            +------------------------------------+------------+
            | Expectation of Unwanted Tracking   | Suspecting |
            +------------------------------------+------------+
            | Access to Resources                | Low        |
            +------------------------------------+------------+
            | Access to Technological Safeguards | High       |
            +------------------------------------+------------+

                                  Table 2

            +=======================+=========================+
            | Other Characteristics | Avocado and Mango       |
            +=======================+=========================+
            | Accessory Usage       | Attacker Only           |
            +-----------------------+-------------------------+
            | Tag Placement         | In Proximity (on child) |
            +-----------------------+-------------------------+

                                  Table 3

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3.3.1.2.  Scenario 2

3.3.1.2.1.  Narrative

   Strawberry and Elderberry live together.  Neither has any specialized
   technological knowledge.  Strawberry has noticed that Elderberry has
   become excessively jealous – every time they go to visit a friend by
   themselves, Elderberry accuses them of infidelity.  To their alarm,
   over the last week, on multiple occasions, Elderberry has somehow
   known which friend they visited at any given time and has started to
   harass the friends.  Strawberry eventually gets a notification that a
   Tag is traveling with them, and thinks it may be in their car, but
   they cannot find it.  They live in a car-dependent area and cannot
   visit friends without the car, and Elderberry controls all of the
   “family” money, so they cannot take the car to the mechanic without
   Elderberry knowing.

3.3.1.2.2.  Analysis

   Here, the Attacker and the Target are still cohabiting, and the
   Attacker is monitoring the Target’s independent activities.  This
   would allow the Attacker to know if, for instance, the Target went to
   a police station or a domestic violence agency.  The Target has
   reason to think that they are being tracked, but they cannot find the
   Tag. This can happen if the sound emitted by the Tag is
   insufficiently loud, and is particularly a risk in a car, where seat
   cushions or other typical features of a car may provide sound
   insulation for a hidden Tag. The Target could benefit from having a
   mechanism to increase the volume of the sound emitted by the Tag.
   Another notable feature of this scenario is that because of the
   cohabitation, the Tag will spend most of the time in “near-Owner
   state” as defined by the proposed industry consortium specification
   (see [I-D.detecting-unwanted-location-trackers]).  Tags do not
   provide alerts in near-Owner state to reduce false positives.

                   +=====================+============+
                   | Attacker Profile    | Elderberry |
                   +=====================+============+
                   | Expertise Level     | Non-Expert |
                   +---------------------+------------+
                   | Proximity to Target | High       |
                   +---------------------+------------+
                   | Access to Resources | High       |
                   +---------------------+------------+

                                 Table 4

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        +====================================+===================+
        | Target Profile                     | Strawberry        |
        +====================================+===================+
        | Expertise Level                    | Non-Expert        |
        +------------------------------------+-------------------+
        | Expectation of Unwanted Tracking   | Suspecting        |
        +------------------------------------+-------------------+
        | Access to Resources                | Low               |
        +------------------------------------+-------------------+
        | Access to Technological Safeguards | Impaired (cannot  |
        |                                    | hear alert sound) |
        +------------------------------------+-------------------+

                                 Table 5

           +=======================+===========================+
           | Other Characteristics | Elderberry and Strawberry |
           +=======================+===========================+
           | Accessory Usage       | Attacker Only             |
           +-----------------------+---------------------------+
           | Tag Placement         | In Proximity (car)        |
           +-----------------------+---------------------------+

                                  Table 6

3.3.1.3.  Scenario 3

3.3.1.3.1.  Narrative

   Lime and Lemon have been dating for two years.  Lemon works for a
   tech company and often emphasizes how much more they know about
   technology than Lime, who works at a restaurant.  Lemon insists on
   having access to Lime’s computer and Android phone so that they can
   “make sure they are working well and that there are no dangerous
   apps.” Lemon hits Lime when angry and has threatened to out Lime as
   gay to their conservative parents and report them to Immigration &
   Customs Enforcement if Lime “talks back.” Lime met with an advocate
   at a local domestic violence program to talk about going to their
   shelter once a bed was available.  The advocate did some safety
   planning with Lime, and mentioned that there is an app for Android
   that can scan for location Tags, but Lime did not feel safe
   installing this app because Lemon would see it.  The next time Lime
   went to see the advocate, they chose a time when they knew Lemon had
   to be at work until late to make sure that Lemon did not follow them,
   but when Lemon got home from work they knew where Lime had been.

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3.3.1.3.2.  Analysis

   This is a case involving a high-skill Attacker, with a large skill
   difference between Attacker and Target.  This situation often arises
   in regions with a high concentration of technology industry workers.
   It also may be more common in ethnic-cultural communities with high
   representation in the technology industry.  In this case the Target
   is also subject to a very high level of control from the Attacker due
   to their imbalances in technological skills and societal status, and
   is heavily constrained in their options as a result.  It is unsafe
   for the Target to engage in active scanning, or to receive alerts on
   their phone.  The Target might benefit from being able to log into an
   account on another phone or a computer and view logs of any recent
   alerts collected through passive scanning.

                     +=====================+========+
                     | Attacker Profile    | Lemon  |
                     +=====================+========+
                     | Expertise Level     | Expert |
                     +---------------------+--------+
                     | Proximity to Target | High   |
                     +---------------------+--------+
                     | Access to Resources | High   |
                     +---------------------+--------+

                                 Table 7

            +====================================+============+
            | Target Profile                     | Lime       |
            +====================================+============+
            | Expertise Level                    | Non-Expert |
            +------------------------------------+------------+
            | Expectation of Unwanted Tracking   | Suspecting |
            +------------------------------------+------------+
            | Access to Resources                | Low        |
            +------------------------------------+------------+
            | Access to Technological Safeguards | Low        |
            +------------------------------------+------------+

                                  Table 8

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                +=======================+================+
                | Other Characteristics | Lemon and Lime |
                +=======================+================+
                | Accessory Usage       | Attacker Only  |
                +-----------------------+----------------+
                | Tag Placement         | Unclear        |
                +-----------------------+----------------+

                                 Table 9

3.3.1.4.  Scenario 4

3.3.1.4.1.  Narrative

   Banana is a social media influencer.  Fig is one of Banana's
   followers, and has become increasingly obsessed with Banana.  Banana
   has no technical background.  Fig has no formal technical background,
   but does read some online forums.  Banana keeps a Location-tracking
   Tag on their keyring to prevent loss or theft of their home and car
   keys.  Fig learns, from reading an online forum, how to find leaked
   passwords in data breaches, and is able to find the password to the
   account associated with Banana's Tag. Using the Crowdsourced Network,
   Fig is able to find Banana's home address and track their location.
   Fig makes a plan to travel to Banana's home and approach them in
   person.

3.3.1.4.2.  Analysis

   This scenario differs from the previous ones in three major ways.
   First, it requires no physical proximity between the Attacker and the
   Target.  Second, the Attacker, like nearly one in five stalkers
   (SPARC - Stalking Infographic, 2022)
   (https://www.stalkingawareness.org/wp-content/uploads/2022/04/
   General-Stalking-Infographic.pdf), is a stranger.  Third, in this
   scenario the Accessory belongs to the Target rather than the
   Attacker.  The Attacker was able to use OSINT learned from an online
   forum in order to gain remote access to the Target's Accessory.

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                   +=====================+============+
                   | Attacker Profile    | Fig        |
                   +=====================+============+
                   | Expertise Level     | Non-Expert |
                   +---------------------+------------+
                   | Proximity to Target | Low        |
                   +---------------------+------------+
                   | Access to Resources | Unknown    |
                   +---------------------+------------+

                                 Table 10

           +====================================+==============+
           | Target Profile                     | Banana       |
           +====================================+==============+
           | Expertise Level                    | Non-Expert   |
           +------------------------------------+--------------+
           | Expectation of Unwanted Tracking   | Unsuspecting |
           +------------------------------------+--------------+
           | Access to Resources                | Unknown      |
           +------------------------------------+--------------+
           | Access to Technological Safeguards | Unknown      |
           +------------------------------------+--------------+

                                  Table 11

                +=======================+================+
                | Other Characteristics | Fig and Banana |
                +=======================+================+
                | Accessory Usage       | Target Only    |
                +-----------------------+----------------+
                | Tag Placement         | On Target      |
                +-----------------------+----------------+

                                 Table 12

3.3.1.5.  Scenario 5

3.3.1.5.1.  Narrative

   Orange and Grapefruit are university students in computer science.
   They attend multiple classes together, and are acquainted but do not
   regularly socialize or live in the same dormitory.  Both use
   Location-tracking Tags to avoid losing items, as do many students at
   the university.  Grapefruit has become increasingly obsessed with
   Orange, though Orange does not realize it.  Grapefruit places
   Location-tracking Tags in Orange's backpack and car.  Orange found
   the one in their backpack after receiving a notification, but was not

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   suspicious when Grapefruit said that they had dropped it.  Orange has
   not used their car in a week and is unaware of the well-hidden Tag
   there.  Grapefruit has created a new account to associate with their
   backup phone and plans to associate multiple Tags with it, in order
   to place them on other possessions of Orange's.

3.3.1.5.2.  Analysis

   In this scenario involving two technical students, the Attacker, like
   over 40% of stalkers (SPARC - Stalking Infographic, 2022)
   (https://www.stalkingawareness.org/wp-content/uploads/2022/04/
   General-Stalking-Infographic.pdf), is an acquaintance.  Both Attacker
   and Target are familiar with and use tracking Accessories.  The
   Attacker is using multiple Accessories with a plan to incorporate
   more into their strategy.

                   +=====================+============+
                   | Attacker Profile    | Grapefruit |
                   +=====================+============+
                   | Expertise Level     | Expert     |
                   +---------------------+------------+
                   | Proximity to Target | Medium     |
                   +---------------------+------------+
                   | Access to Resources | High       |
                   +---------------------+------------+

                                 Table 13

           +====================================+==============+
           | Target Profile                     | Orange       |
           +====================================+==============+
           | Expertise Level                    | Expert       |
           +------------------------------------+--------------+
           | Expectation of Unwanted Tracking   | Unsuspecting |
           +------------------------------------+--------------+
           | Access to Resources                | High         |
           +------------------------------------+--------------+
           | Access to Technological Safeguards | High         |
           +------------------------------------+--------------+

                                  Table 14

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              +=======================+=====================+
              | Other Characteristics | Fig and Banana      |
              +=======================+=====================+
              | Accessory Usage       | Attacker and Target |
              +-----------------------+---------------------+
              | Tag Placement         | Multiple Types      |
              +-----------------------+---------------------+

                                  Table 15

3.3.2.  Bluetooth vs. other technologies

   The above taxonomy and threat analysis focus on Location-tracking
   Tags.  They are protocol-independent; if a Tag were designed for use
   with a Crowdsourced Network using a technology other than Bluetooth,
   they would still apply.  The key attributes are the functionalities
   and physical properties of the Accessory from the user’s perspective:
   the Accessory must be small, not Easily Discoverable, and able to
   participate in a Crowdsourced Network.  While many GPS based location
   trackers are not explicitly designed for crowdsourced location-
   tracking, relying instead on cellular or satellite transmission, they
   offer different affordances that can have a critical impact on
   safety, including increased location precision and real-time
   tracking.  Manufacturers of these trackers are strongly encouraged to
   add Bluetooth crowdsourced functionality so that DULT Protocols can
   be supported by GPS trackers.

3.4.  Possible Attacks on the DULT Protocol

   There are several different ways an Attacker could attempt to
   circumvent the DULT Protocol in order to track a Target without their
   consent or otherwise take advantage of the Crowdsourced Network.
   These include deploying multiple Tags to follow a single Target,
   using non-conformant Accessories and/or Devices, and taking advantage
   of possible differences between Crowdsourced Network implementations.
   This section includes a threat prioritization framework that assesses
   the risk of these attacks and how these risks may be mitigated.

3.4.1.  Threat Prioritization Framework for DULT Threat Model

   Threats in the DULT ecosystem vary in severity, feasibility, and
   likelihood, affecting users in different ways.  Some threats enable
   long-term tracking, while others exploit gaps in detection mechanisms
   or leverage non-conformant Accessories and Devices.  To assess and
   prioritize these risks, the following framework classifies threats
   based on their scope, impact, likelihood, risk level, affected users,
   and the availability of mitigations.  A Threat Matrix is included
   that provides a structured assessment of known threats and their

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   associated risks.  This categorization helps in understanding the
   challenges posed by different tracking techniques and their potential
   mitigations.  While each attack included in this section only
   includes one value for potential impact, likelihood and risk level,
   in practice these values could differ depending on considerations
   discussed in Section 3.3 such as the proximity of the Attacker to the
   Target.

3.4.2.  Threat Matrix

   To systematically assess the risks associated with different threats,
   we introduce the following threat matrix.  This categorization
   considers the following factors:

   *  Scope: The DULT WG document(s) most relevant to the attack.

      -  Accessory: The Accessory protocol document, which describes the
         DULT Non-Owner Device protocol and other requirements for
         Accessories.

      -  Finding: The finding algorithm document, which describes the
         DULT algorithm(s) to be implemented by Platforms/Devices.

      -  Network: The Crowdsourced Network document, which describes the
         architecture of the Crowdsourced Network and includes guidance
         for Platforms/Devices.

   *  Impact: The potential consequences of the threat if successfully
      executed.

      -  Low: Minimal effect on privacy and security.

      -  Medium: Moderate effect on user privacy or tracking protection.

      -  High: Severe privacy violations or safety risks.

   *  Likelihood: The probability of encountering this threat in real-
      world scenarios.  This includes both the frequency of the attack
      and how easy it is to execute.

      -  Low: Rare or requires specific conditions and high technical
         effort.

      -  Medium: Possible under common scenarios with moderate technical
         requirements.

      -  High: Frequently occurring or easily executed using common
         tools or skills.

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   *  Risk Level: A qualitative assessment based on impact and
      likelihood.

      -  Low: Limited risk requiring minimal mitigation.

      -  Medium: Requires mitigation to prevent common attacks.

      -  High: Critical threat must be addressed.

   *  Affected Users: These are categorized as either:

      -  Targets: Individuals specifically targeted for the purposes of
         Unwanted Tracking.

      -  All users: Anyone using the system, even if they are not
         directly targeted.

   *  Mitigation Available?: Whether a known mitigation strategy exists.

      -  Yes: A viable mitigation exists.

      -  Partial: Some mitigations exist, but are not fully effective.

      -  No: No effective mitigation currently available.

   +=============+==========+======+==========+======+========+==========+
   |Threat       |Scope     |Impact|Likelihood|Risk  |Affected|Mitigation|
   |             |          |      |          |Level |Users   |Available?|
   +=============+==========+======+==========+======+========+==========+
   |Deploying    |Finding   |Medium|High      |High  |Targets |Yes       |
   |Multiple Tags|          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Remote       |Accessory,|Medium|High      |Medium|All     |Partial   |
   |Advertisement|Network   |      |          |      |users   |          |
   |Monitoring   |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Physically   |Accessory |High  |Medium    |Medium|Targets |Partial   |
   |Modifying    |          |      |          |      |        |          |
   |Tags         |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Accessory    |Accessory |High  |Low/Medium|High  |Targets |Partial   |
   |Firmware     |          |      |          |      |        |          |
   |Modifications|          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Attacker     |Accessory,|Medium|Medium    |Medium|Targets |Partial   |
   |Accessory    |Finding   |      |          |      |        |          |
   |Disablement  |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+

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   |Tracking     |Network   |High  |Medium    |High  |Targets |Partial   |
   |Using        |          |      |          |      |        |          |
   |Target's Own |          |      |          |      |        |          |
   |Tag          |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Disabling    |Network   |High  |Medium    |Medium|Targets |Partial   |
   |Target Tag   |          |      |          |      |        |          |
   |Detection    |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Disabling    |Accessory,|Medium|Medium    |Medium|Targets |Partial   |
   |Target Tag   |Network   |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Impersonation|Accessory,|High  |Medium    |High  |Targets |Partial   |
   |Attack (Tag) |Finding,  |      |          |      |        |          |
   |             |Network   |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Impersonation|Accessory,|High  |Medium    |High  |All     |Partial   |
   |Attack       |Network   |      |          |      |users   |          |
   |(Device/Tag) |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Impersonation|Network   |Medium|Low/Medium|Low   |All     |Partial   |
   |Attack       |          |      |          |      |users   |          |
   |(Device/     |          |      |          |      |        |          |
   |Network)     |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Replay Attack|Accessory,|Medium|High      |Medium|All     |Partial   |
   |             |Network   |      |          |      |users   |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Heterogeneous|Accessory,|High  |Medium    |Medium|Targets |No        |
   |Tracker      |Finding,  |      |          |      |        |          |
   |Networks     |Network   |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+
   |Deploying GPS|Accessory |High  |Medium    |High  |Targets |Partial   |
   |Tracker      |          |      |          |      |        |          |
   +-------------+----------+------+----------+------+--------+----------+

                                  Table 16

3.4.3.  Deploying Multiple Tags (Finding)

   When an Attacker deploys Location-tracking Tags to follow a Target,
   they may deploy more than one Tag. For example, if planting a
   tracking Tag in a car, the Attacker might place one Tag inside the
   car, and another affixed on the outside of the car.  The DULT
   Protocol must be robust to this scenario.  This means that scans,
   whether passive or active, need to be able to return more than one
   result if a Tag is suspected of being used for Unwanted Tracking, and
   the time to do so must not be significantly impeded by the presence

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   of multiple Tags.  This also applies to situations where many Tags
   are present, even if they are not being used for Unwanted Tracking,
   such as a busy train station or airport where Tag Owners may or may
   not be in proximity to their Location-tracking Tags.  Instead of
   distributing multiple Tags in the same location, an Attacker could
   also distribute multiple Location-tracking Tags across locations
   frequently visited by a Target (home, workplace, etc.).

   The impact of this attack is medium for typical cases involving a
   small number of Tags, though the impact could escalate if an Attacker
   deploys dozens of Tags.  The likelihood is high, as deploying
   multiple Tags requires minimal technical effort and can be done using
   inexpensive, commercially available Tags, making the attack easily
   repeatable.  As a result, the overall risk is high, requiring robust
   countermeasures.  The impact of multiple Tags can be fully mitigated
   by scanning for multiple Tags, though a sophisticated Attacker might
   deploy other techniques such as modifying Tag firmware
   (Section 3.4.6) or periodically disabling a Tag (Section 3.4.7) to
   evade detection.

3.4.4.  Remote Advertisement Monitoring (Accessory, Network)

   Any Device with Bluetooth scanning capabilities in proximity to a
   Location-tracking Tag can receive Bluetooth advertisement packets.
   If an Attacker is able to link an identifier in an advertisement
   packet to a particular Tag, they may be able to use this information
   to track the Tag over time, and by proxy the Target or other
   individual, without their consent.

   The impact of remote advertisement monitoring is moderate, as
   tracking generally compromises privacy but, in many cases, prolonged
   observation primarily reveals the location of the object rather than
   of the person.  The likelihood is high, as Attackers can execute this
   using off-the-shelf Bluetooth scanning tools or smartphone apps with
   minimal technical knowledge.  As a result, this is classified as a
   medium risk attack.  This attack can be partially mitigated by
   rotating tracking identifiers.

   Tracking Tags typically rotate any identifiers associated with the
   Tag, with the interval depending on context: when near the Owner's
   Device, identifiers rotate frequently (every 15–30 minutes), while in
   a separated state, rotation may occur only once every 24 hours (see
   [I-D.detecting-unwanted-location-trackers]).  Eldridge et al. have
   demonstrated (https://eprint.iacr.org/2023/1332.pdf) a technological
   solution that employs secret sharing and error correction coding that
   would reduce this to 60 seconds.  However, work must investigate how
   robust this scheme is to the presence of multiple Tags (see
   Section 3.4.3).

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   While rotating identifiers provides partial mitigation, Attackers can
   still use advanced correlation techniques, such as signal
   fingerprinting, timing analysis, and multi-sensor triangulation, to
   bypass this defense.  These methods leverage unique transmission
   characteristics, RSSI (Received Signal Strength Indicator)
   variations, and environmental factors to probabilistically link
   rotating identifiers back to a single Tag over time.  Prior research,
   such as Eldridge et al., has demonstrated
   (https://eprint.iacr.org/2023/1332.pdf) how statistical models can be
   used to correlate Bluetooth signals even when identifiers change
   frequently.  Additional work by Despres et al. further demonstrates
   (https://people.eecs.berkeley.edu/~daw/papers/deTagtive-snip23.pdf)
   that BLE Accessories using rotating identifiers can be deanonymized
   through RSSI-based correlation techniques.

3.4.5.  Physically Modifying Tags (Accessory)

   An Attacker might physically modify a Tag in ways that make it non-
   conformant with the DULT Protocol.  Physical modifications may
   include disabling a speaker or other haptics, or shielding and
   altering the antenna to reduce transmission range.  These
   modifications can make it more difficult for Victims to discover
   hidden Tags, leading to a high impact.  The likelihood is medium, as
   such hardware modifications require moderate technical expertise and
   physical access to the Tag.  Given this combination of factors, the
   overall risk level is medium.  Partial mitigation is available, such
   as monitoring the impedance of the speaker, but these mitigations are
   limited as Attackers have physical access to the Tags.

3.4.6.  Accessory Firmware Modifications (Accessory)

   The DULT Protocol (see [I-D.draft-ietf-dult-accessory-protocol]) will
   specify that Accessory firmware images MUST be authenticated, and
   that Accessories MUST verify the integrity and origin of firmware.
   However, if these protections were to be bypassed, an Accessory's
   firmware could be altered to deviate from standard behavior.
   Attackers may manipulate advertisement intervals to reduce detection
   opportunities, allowing the Tag to evade tracking for extended
   periods, or rotate IDs rapidly, disrupting detection systems that
   rely on tracking unknown Accessory persistence.

   Firmware-based changes would have high impact.  The likelihood is
   typically low, as these attacks require significant technical
   expertise to bypass firmware verification and modify low-level
   Accessory behavior.  However, once a vulnerability has been
   discovered and distributed, the likelihood could increase to medium
   as it would only require the technical ability to deploy the attack.
   It will be important for Accessory firmware to be able to be patched

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   to address vulnerabilities.  As a result, the overall risk level is
   high.  Partial mitigation of this attack is possible by requiring
   Accessories to verify the integrity and origin of firmware.

3.4.7.  Attacker Accessory Disablement (Accessory, Finding)

   An Attacker might intentionally disable their Location-tracking Tag
   to make it harder for a Victim to detect and/or locate the Tag. This
   could be done periodically or permanently and either remotely or
   using a physical device (https://undetecTag.com/products/undetecTag).

   The likelihood is medium, as this attack is relatively easy to
   perform using commercially available tools, but it still requires
   some Attacker awareness of the Target’s actions (e.g., an ongoing
   search).  The impact is medium as the Tag can still be detected and
   physically located, though it may be more difficult to do so.  The
   risk level is medium.  The impact of this attack can be partially
   mitigated by minimizing the time needed to detect Unwanted Tracking
   and maintaining the same identifier on reset.

3.4.8.  Tracking Using Target's Own Tag (Network)

   Attackers with access to a Target’s account, either through password
   reuse, phishing, social engineering, or credential theft, can exploit
   DULT’s Ownership model by using the Target’s own Tag to monitor their
   location.  Since the Tag is registered to the Target, the system
   assumes the user is the legitimate Owner and suppresses any Unwanted
   Tracking alerts.  This creates a significant blind spot, as the
   Target is effectively tracked by their own Tag without any warning.

   This threat differs from impersonation or replay attacks (see
   Section 3.4.11 and Section 3.4.13) because it does not rely on
   breaking cryptographic protections or evading detection algorithms.
   Instead, it leverages the legitimate trust relationship encoded in
   the protocol.  The impact of this attack is high, as it results in
   silent tracking with no alert mechanism.  The likelihood is medium,
   as account compromise is a relatively common occurrence in real-world
   settings, though it still requires some Attacker effort or
   opportunity.  Overall, the risk level is high due to the complete
   circumvention of core notification systems.

   Partial mitigation may be possible through account activity
   monitoring, anomaly detection (e.g., login from unfamiliar location
   or Device), and notifications of significant account events (such as
   Tag access or Tag movement linked to a different Device).  However,
   these features depend on Platform implementation and may not be
   uniformly enforced.

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3.4.9.  Disabling Target Tag Detection (Network)

   An Attacker might intentionally disable passive Unwanted Tracking
   detection on a Target's Device.

   The impact of this attack is high as it would prevent the Target from
   being notified about possible Unwanted Tracking.  The likelihood is
   medium, as executing this attack requires the Attacker to physically
   or remotely alter settings on the Target’s Device, which involves
   moderate effort and access.  The risk level is medium.  This attack
   can be partially mitigated by notifying Targets of potential location
   tracking using other means e.g. sounds or haptics on Location-
   tracking Tags.

3.4.10.  Disabling Target Tag (Accessory, Network)

   An Attacker might intentionally disable a Target's Tag as a form of
   harassment.  This could be done with physical access to the Tag,
   using a Target's own Device to disable the Tag, or with remote access
   to disable the Tag via the Crowdsourced Network.  The impact of this
   attack is medium as it is a nuisance but most likely does not involve
   a security threat, unless the Tag is being used to track a valuable
   item or child.  The likelihood is medium, as executing the attack
   requires access to the Target’s Tag, Device, or account, which
   involves a moderate level of access or effort.  The risk level is
   therefore medium.  Physical disablement of a Tag cannot be mitigated,
   but other forms of disablement may be mitigated by notifying users
   that a change has been made on their account, similar to suspicious
   login notifications.

3.4.11.  Impersonation Attack (Tag; Accessory, Finding, Network)

   Attackers might be able to impersonate legitimate tracking
   Accessories, enabling tracking without complying with the DULT
   Protocol.  This can be done by deploying custom Tags
   (https://www.hackster.io/news/fabian-braunlein-s-esp32-powered-find-
   you-Tag-bypasses-apple-s-airTag-anti-stalking-protections-
   0f2c9ee7da74) or by using Devices to mimic Tags (https://cec.gmu.edu/
   news/2025-02/find-my-hacker-how-apples-network-can-be-potential-
   tracking-tool).  By impersonating an authorized Tag, an Attacker
   could inject false location data, misattribute Tag Ownership, or
   evade detection by appearing as a trusted Accessory or rotating
   identifiers frequently.  This tactic increases the difficulty of
   accurately identifying unauthorized tracking attempts and undermines
   the reliability of the network.

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   In addition to full impersonation, adversaries may exploit Platform-
   specific assumptions to suppress alerts.  For instance, Chen et al.
   describe
   (https://www.usenix.org/system/files/conference/usenixsecurity25/
   sec25cycle1-prepub-1266-chen-junming.pdf) a technique in which an
   Attacker sets the status field of a broadcast message to 0x00 to
   emulate MacBook location beacons.  Since such beacons are typically
   ignored by Apple’s Unwanted Tracking alerts, this evasion method
   allows the Attacker to remain undetected.  This demonstrates how
   Attackers can exploit trust assumptions about certain Accessory
   classes to bypass user protections, further complicating detection
   and mitigation.

   The impact of this attack is high, as it enables real-time location
   tracking by exploiting the behavior of the Crowdsourced Network.  The
   likelihood is medium, as the attack requires deploying custom
   hardware or exploiting Platform-specific capabilities like
   unrestricted Bluetooth broadcasting, which have been demonstrated in
   research but remain moderately complex to execute.  As a result, the
   overall risk level is considered high.  Currently, no fully effective
   mitigation exists.  However, improvements in authentication
   mechanisms, such as cryptographic signing of broadcasts, and anomaly
   detection techniques may help reduce the risk.  Protocol-level
   authentication is needed to validate Accessory identities and prevent
   these attacks.  Operating systems can partially mitigate software
   impersonation attacks by restricting low-level BLE broadcasting
   unless elevated privileges are granted.

3.4.12.  Impersonation Attack (Device)

   In addition to impersonating a Tag, an Attacker could also
   impersonate a Device.  This affords attacks against both Accessories
   and against the Crowdsourced Network.

3.4.12.1.  Attacks on Accessories (Accessory, Network)

   Any Bluetooth transmitter can theoretically send arbitrary commands
   to Accessories.  Accessory firmware therefore must attempt to verify
   the authenticity of commands from Devices or otherwise limit how
   Accessories respond to commands from Devices.  For example,
   Accessories that receive a "play sound" command from a Non-Owner
   Device should only execute the command if the Accessory is away from
   its Owner.  Similarly, Accessories should only respond to remote
   disablement commands if the Accessory can confirm it is likely being
   used for Unwanted Tracking and the Accessory can confirm that a
   Device has used other finding techniques to locate the Accessory.
   However, if an Attacker is able to circumvent the DULT protocol and
   transmit arbitrary commands to Accessories, said Attacker could have

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   high impact on the functioning of individual Accessories and/or the
   Crowdsourced Network.

   The impact of a Device impersonation attack is high if it is able to
   send arbitrary commands to Accessories.  The likelihood of such an
   attack is medium; it can be done by any Device able to transmit BTLE
   packets, but requires some familiarity with the DULT Protocol or
   technical awareness to deploy a pre-packaged attack.  Therefore, the
   overall risk level is high.  The affected users are all users.
   Mitigation is partial; while Devices cannot be prevented from
   transmitting packets, certain rules can be enforced by Accessories.

3.4.12.2.  Attacks on Crowdsourced Network (Network)

   An impersonated Device could send false location reports to the
   Crowdsourced Network, or selectively not report to the Crowdsourced
   Network.

   The likelihood of this attack is low, as it would require the
   impersonated Device to authenticate with the Crowdsourced Network.
   The likelihood could increase to medium if a pre-packaged and
   unpatched attack were discovered.  The impact is medium, as not
   reporting would have negligible impact and false location reports are
   a nuisance but can be mitigated.  The overall risk level for this
   attack is low even in circumstances of a pre-packaged attack as there
   are many mitigations available.  The affected users are all users.
   Mitigations include requiring authentication to send reports to the
   Crowdsourced Network and only trusting reports when they can be
   verified by multiple Devices.

3.4.13.  Replay Attack (Accessory, Network)

   In addition to impersonating legitimate Accessories (see
   Section 3.4.11), Attackers can record and replay Bluetooth
   advertisements from a legitimate Accessory.  For example, an Attacker
   could capture an Accessory's broadcast and retransmit it elsewhere,
   creating confusion about its actual location.  This could be used to
   mislead users, interfere with tracking accuracy, or frame an innocent
   party by making it appear as though they are carrying an Accessory or
   in a location when they are not.

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   The impact of this attack is medium.  The likelihood is high, as
   replay attacks require no authentication and can be executed using
   off-the-shelf Bluetooth scanning tools with minimal technical
   expertise.  Replay attacks pose a medium risk owing to their higher
   likelihood but medium impact.  Replay attacks are particularly
   difficult to mitigate as they may involve different combinations of
   Accessories and Devices.  Partial mitigation may be possible by
   authenticating messages from Accessories in a time varying manner.

3.4.14.  Heterogeneous Tag Networks (Accessory, Finding, Network)

   Attackers may use a mix of Tags from different manufacturers (e.g.,
   Apple AirTags, Tile, Samsung SmartTags) to exploit gaps in vendor-
   specific tracking protections.  Many detection systems are brand-
   dependent, making them ineffective against mixed Tag deployments.
   The goal of the DULT Protocol is to enable a cross-vendor framework;
   however, any slight differences in implementation could be exploited.

   The impact is high, as it circumvents traditional defenses.  The
   likelihood is medium, as deploying or selecting from multiple brands
   requires effort and coordination, and may demand deeper knowledge of
   Platform-specific behaviors and limitations.  Overall, this is medium
   risk attack.  This attack can be mitigated by manufacturers adopting
   the DULT Protocol and ensuring that the DULT Protocol is sufficiently
   clear to minimize gaps in vendor-specific tracking protections.

3.4.15.  Deploying GPS Tracker (Accessory)

   When an Attacker deploys a GPS tracker to stalk a Target, they have
   access to greater location precision, real-time tracking, and even
   global coverage through satellite connection for some trackers.
   Attackers are especially likely to use GPS trackers in rural areas
   and areas with low Crowdsourced Network saturation, or when looking
   for more advanced precision or for Accessories that do not offer
   safety protections.

   The impact of this attack is high due to the increased location
   precision and real-time tracking functionality.  The likelihood is
   medium, as these trackers are currently more expensive than Bluetooth
   based trackers, and not as readily available.  As a result, the
   overall risk is high, requiring robust countermeasures.  The impact
   of GPS trackers can be mitigated by adding Bluetooth crowdsourced
   location-tracking functionality to GPS trackers and adopting the DULT
   Protocol.  However, the adoption of the DULT Protocol by GPS tracker
   manufacturers is of course optional, so this is considered a partial
   mitigation.

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3.5.  Scope and Priorities for the DULT WG

3.5.1.  Technologies

   The scope of this threat analysis includes any Accessory that is
   small and not Easily Discoverable and able to transmit its location
   to consumer Devices using Bluetooth.  Larger and/or Easily
   Discoverable Accessories/Devices such as laptops with location-
   tracking integrations may also choose to implement the protocol.

3.5.2.  Attacker Profiles

   An Attacker who deploys any of the attacks described in Section 3.4.1
   is considered in scope.  This includes: Attackers who track Victims
   using a Location-tracking Tag and applications readily available for
   end-users (e.g. native tracking application), Attackers who
   physically modify Location-tracking Tags (e.g. to disable a speaker),
   and Attackers who make alterations to the firmware of an existing
   tracking Tag or create custom Tags that successfully connect to
   Devices and therefore the Crowdsourced Network.

3.5.3.  Target Profiles

   All Targets profiles are in scope regardless of their expertise,
   access to resources, or access to technological safeguards.  For
   example, protocols should account for a Target's lack of access to a
   smartphone, and scenarios in which Targets cannot install separate
   software.

3.5.4.  Priorities

   The technical documents of the DULT WG should consider all of the
   scenarios discussed in Section 3.3.1.  When it comes to attacks,
   while all attacks on the DULT protocol are considered to be in scope,
   the following attacks are the highest risk and therefore considered
   the highest priority for the DULT WG to address:

   *  Deploying Multiple Tags (Section 3.4.3)

   *  Accessory Firmware Modifications (Section 3.4.6)

   *  Tracking Using Target's Own Tag (Section 3.4.8)

   *  Impersonation Attack (Tag) (Section 3.4.11)

   *  Impersonation Attack (Device/Tag) (Section 3.4.12.1)

   *  Deploying GPS Tracker (Section 3.4.15)

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   See Section 3.4.2 for a full list of attacks.

4.  Design Considerations

   As discussed in Section 3, Unwanted Tracking can involve a variety of
   Attacker, Target, and Tag profiles.  A successful implementation to
   preventing Unwanted Tracking should:

   *  Include a variety of approaches to address different scenarios,
      including active and passive scanning and notifications or sounds

   *  Account for scenarios in which the Attacker has high expertise,
      proximity, and/or access to resources within the scope defined in
      Section 3.5

   *  Account for scenarios in which the Target has low expertise,
      access to resources, and/or access to technological safeguards
      within the scope defined in Section 3.5

   *  Avoid privacy compromises for Tag Owner(s) when protecting against
      Unwanted Tracking.  The privacy of Tag Owner(s) and the security
      of Targets should be considered equally.

   In the sections below, we first discuss limitations of existing
   approaches to detecting and preventing Unwanted Tracking, and then
   outline design requirements, design constraints, and priorities for
   the DULT WG moving forward.

4.1.  Limitations of existing approaches to detecting and preventing
      Unwanted Tracking

   This section outlines several limitations of existing approaches to
   detecting and preventing Unwanted Tracking as of the time of writing.
   This includes six different areas:

   1.  Spotty Implementation

   2.  Lack of customizability

   3.  Difficulty finding and disabling Tags

   4.  Nonconformant Accessories

   5.  Activities Logs

   6.  Anti-theft mode

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   A successful implementation of the DULT protocol would consider each
   of these limitations as described in the relevant sections below.

4.1.1.  Spotty Implementation

   In current implementations of the DULT protocol, implementations of
   safeguards against Unwanted Tracking are inconsistent across
   Platforms and Devices.  For example, the types and methods of
   obtaining Unwanted Tracking Alerts vary.  Current Accessory types
   also vary widely in the amount and type of information they provide
   to a Target who has detected a possible unwanted tracker actively or
   passively.  This creates a situation where a Target’s ability to
   mitigate threats to their safety depends on consumer choices and
   access.

   As of this writing, major platforms do not currently implement both
   Active and Passive Scanning.  Android users (including users of
   devices with operating systems derived from Android OS, such as
   Amazon’s FireOS) can actively scan for an Accessory, but passive
   scanning is not supported. iOS users can receive potential Unwanted
   Tracking Alerts generated through Passive Scanning, but cannot
   actively scan for Accessories.  Because of this, protections are
   contingent on both the type of Tag and the type of scanning Device.
   These inconsistencies place a higher burden on targets of abuse to
   find information specific to products, and create challenges in
   creating easily understandable public safety information.  These
   differences can also be exploited by an Attacker familiar with target
   Platforms.  A successful protocol would support both Active and
   Passive Scanning as this increases options for Targets who may be
   dealing with highly individualized situations.

   The information provided in Unwanted Tracking Alerts, and the options
   for a Target, would benefit from standardization across Platforms and
   Devices.  Currently, Accessories made by different manufacturers
   provide different amounts and types of information in detection
   reports, with different options available to targets.  This is easily
   exploited by an attacker familiar with the differences in Unwanted
   Tracking Alerts.

4.1.2.  Lack of customizability

   Potential Targets’ ability to customize Unwanted Tracking Alerts is
   currently limited, as they cannot control the sensitivity of tracking
   algorithms.  Because Targets have vastly different situations and
   needs, they may benefit from customization options.  Some people may
   develop “alert fatigue” from false positives, while others may be
   more concerned about false negatives.  Some circumstances may also
   raise the likelihood of false positive alerts, such as may happen on

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   public transportation.  As stalking situations often become more or
   less intense over time, potentially with several cycles of intensity,
   the same person may have different needs at different times.  They
   may wish to increase sensitivity in a high risk scenario or
   timeframe, or decrease/disable sensitivity because alerts cause
   anxiety or false positives condition them to ignore alerts.  This
   document recommends options for the customization in the frequency of
   alerts and detection radius for receiving an alert.  A successful
   protocol may also consider whether potential targets should be able
   to customize whether an alert provides a high-level assessment of
   risk level (e.g. “high risk” or “low risk” for a pattern of unwanted
   tracking).

4.1.3.  Difficulty finding and disabling tags

   Location-tracking Tags are small by design and can be difficult to
   locate.  While many Tags have speakers or haptics to help users
   locate Tags, these sounds/vibrations may be difficult to detect
   (especially for users with disabilities) and may also be easy to
   disable.  Advanced features such as Ultra Wide Band (UWB) finding are
   also not supported by all tags and devices/platforms.  This can make
   it difficult for targets to locate Tags.  If a target cannot locate a
   Tag, there is limited recourse as it is also not currently possible
   to remotely disable a Tag (whether over the air using a device or via
   the crowdsourced network).  A successful protocol would consider
   requirements to assist Targets in locating and disabling tags that
   are feasible for Tags, many of which are small and low-cost, and that
   can be implemented without otherwise compromising the Crowdsourced
   Network.

4.1.4.  Nonconformant Tags

   Attackers can deploy a variety of attacks involving Nonconformant
   Tags:

   *  Impersonation attack: Tags could be designed or manipulated to
      impersonate a conformant Tag, but not implement the Unwanted
      Tracking features

   *  Replay attack: a nonconformant Tag could replay packets from a
      conformant Tag

   *  Physical modifications: a conformant Tag could have its physical
      attributes compromised (e.g. disabling a speaker)

   *  Accessory firmware modification: a conformant Tag could have its
      software modified to circumvent Unwanted Tracking features

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   If any of these attacks are successful, attackers may be able to
   authenticate with the Crowdsourced Network via any device, and
   therefore access location information about the tag without complying
   with the DULT protocol.  This could also make it more difficult for
   targets to locate tags.  While it is not possible to limit the
   deployment of nonconformant Tags, a successful protocol would
   minimize the ability of nonconformant Tags to access the crowdsourced
   network.

4.1.5.  Activities Logs

   A successful implementation of the protocol should consider logging
   for two types of events: 1) when an Unwanted Tracking Alert is
   triggered, and 2) when a location of a Tag suspected of Unwanted
   Tracking is accessed via the Crowdsourced Network.  The account and
   device are particularly important as Tags may be shared by multiple
   accounts who may have many different devices.  Logs should not be
   easily editable to avoid gaslighting and accountability efforts.

   At a bare minimum, a successful protocol would include a log file
   that is clearly labeled and easily accessible for users of a Device
   that is not easily edited, clearly labeling the nature of the
   tracking alert.  Each log event should include: the account, the
   Device, GPS location, and the time.  This log should ideally be
   stored on the Device where the alert was triggered.  Ideally, there
   would also be a log file that would also include the times at which
   the owner of the tracker checked its location while the tracker was
   close enough to the device to set off the Unwanted Tracking Alert.
   This would require information from the Crowdsourced Network and it
   may be appropriate to be stored remotely.

4.1.6.  Anti-theft mode

   Tile has implemented an “Anti-Theft” mode that stops the tracker from
   setting off Unwanted Tracking Alerts when a target runs Tile’s “Scan
   and Secure” features on their own device.  Users of this mode must
   agree to a multi-stage ID scan and send in a selfie to Tile for
   verification.  This implementation plainly fails to meet DULT’s
   recommendation that tracking alerts should not be circumventable
   under any circumstance.  The ID verification that a Tile user must
   pass in order to enable “Anti-Theft” mode is an insufficient
   mitigation against stalking because it is only useful if the physical
   item is found by the person being tracked, a circumstance that this
   “Anti-theft” mode is designed to prevent.  Any mode that makes it
   possible to turn off Unwanted Tracking Alerts is antithetical to
   DULT’s recommendations.

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4.2.  Design Requirements

   The DULT Protocol should 1) allow Targets to detect Unwanted
   Tracking, 2) help Targets find Tags that are tracking them while
   minimizing false positives (e.g., avoiding legitimate, co-owned, or
   nearby Tags being misidentified as threats), and 3) provide
   instructions for Targets to disable those Tags if they choose.  These
   affordances should be implemented while considering the appropriate
   privacy and security requirements.

4.2.1.  Detecting Unwanted Location Tracking

   There are four ways that the DULT Protocol should assist Targets in
   detecting potentially Unwanted Tracking: 1) active scanning, 2)
   passive scanning, 3) tracking Tag alerts, and 4) Crowdsourced Network
   activities logs.

4.2.1.1.  Active Scanning

   There may be scenarios where a Target suspects that they are being
   tracked without their consent.  Active scanning should allow a user
   to use a native application on their Device to search for Location-
   tracking Tags that are separated from their Owners.  When a Tag has
   been identified as potentially being used for Unwanted Tracking, the
   user should be able to view the serial number of the Device along
   with Obfuscated Owner Information and instructions on how to find
   and/or disable the Tag (see Section 4.2.2 and Section 4.2.3).
   Additional information about when that Tag has been previously
   encountered within a designated time window (e.g. the last 12 hours)
   should also be included if available (see Section 3.2).  Allowing
   users to "snooze" or ignore Tags known to be safe (e.g. Tags from a
   family member) could also be implemented.  Tracking Tags that are
   near their Owners should not be shared to avoid abuse of the active
   scanning feature.

4.2.1.2.  Passive Scanning

   Platforms should passively scan for Tags suspected of Unwanted
   Tracking and notify the user.  This will involve implementing one or
   more algorithms to use to flag Tags and determine when to notify the
   user.  (A dedicated DULT WG document will address tracking
   algorithms, and will be linked when it is available.)  The user could
   be notified through a push notification or through Sounds and Haptics
   (see Section 4.2.1.3).  When a Tag has been identified as potentially
   being used for Unwanted Tracking, the user should be able to view the
   serial number of the Tag along with Obfuscated Owner Information for
   all accounts linked to the Tag and instructions on how to find and/or
   disable the Tag (see Section 4.2.2 and Section 4.2.3).  There will be

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   tradeoffs between detecting potential Unwanted Tracking promptly and
   alerting the potential Target prematurely.  One way to handle these
   tradeoffs is to allow users to set the sensitivity of these alerts.
   For example, the AirGuard (https://github.com/seemoo-lab/AirGuard)
   app includes three different "Security Level" settings that users can
   customize.

   To improve the accuracy of Unwanted Tracking detection, a confidence
   scoring mechanism can be used.  Instead of issuing binary alerts for
   all detected Tags, the system assigns a confidence score based on
   multiple factors, helping distinguish between genuine tracking
   threats and benign scenarios.  This section outlines potential
   factors that may contribute to assessing the likelihood of Unwanted
   Tracking.  Each factor can be considered independently to help inform
   an overall risk assessment.  A confidence-based approach offers the
   following advantages:

   *  Reduced False Positives: A confidence-based approach can help
      filter out benign tracking scenarios, such as transient signals or
      shared family Tags.  Instead of triggering alerts based solely on
      presence, the system can dynamically adjust its sensitivity based
      on behavioral patterns.  For example, if a tracking Tag appears
      near a user only briefly or follows a predictable shared usage
      pattern (e.g., a Bluetooth Tag frequently used by family members),
      it may be assigned a low confidence score.  This prevents
      unnecessary alerts while still ensuring that persistent and
      anomalous tracking behaviors are flagged for user attention.

   *  Context-Aware Threat Evaluation: The confidence score can
      incorporate contextual factors such as movement patterns, duration
      of proximity, and recurrence.  For instance, if a Tag is detected
      only once in a public place (e.g., at a café or airport), it is
      less likely to indicate malicious tracking.  However, if the same
      Tag reappears near the user across multiple locations or over an
      extended period, its confidence score increases, prompting a
      higher-priority alert.

   *  Adaptive Alert Sensitivity: By dynamically adjusting detection
      thresholds based on confidence scores, the system can prioritize
      high-risk scenarios while minimizing unnecessary alerts.  Users
      may receive warnings based on escalating levels of certainty, such
      as:

      -  Low confidence: Informational notification (e.g., "An
         unfamiliar Tag was briefly detected nearby.")

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      -  Medium confidence: Warning with recommended actions (e.g., "A
         Tag has been detected multiple times near you.  Check your
         surroundings.")

      -  High confidence: Urgent alert with mitigation options (e.g., "A
         Tag has been persistently following you.  Consider removing or
         disabling it.")

   This approach ensures that users receive actionable and meaningful
   alerts, reducing notification fatigue while maintaining strong
   protection against Unwanted Tracking.  The confidence scoring
   approach could include the variables listed below.

4.2.1.2.1.  Duration of Proximity

   Tracks how long a Tag remains in close proximity to the user.

   *Rationale*: Tags that persist near a user for extended periods are
   more likely to indicate tracking activity than transient encounters
   (e.g., passing someone on public transit).

4.2.1.2.2.  Movement Correlation

   Measures how closely the movement of the suspected Tag mirrors that
   of the user.

   *Rationale*: High movement correlation (e.g., appearing at home, then
   work, then a store with the user) increases the likelihood that the
   Tag is following the user intentionally.

4.2.1.2.3.  Signal Strength Trends

   Observes how the signal strength of the suspected Tag (e.g.,
   Bluetooth RSSI) changes over time.

   *Rationale*: A sustained or increasing signal strength suggests
   physical proximity to the user, strengthening the case for
   intentional tracking.

4.2.1.2.4.  Persistence

   Evaluates how often and across how many different times/locations the
   same Tag is observed, while accounting for identifier rotation.

   *Rationale*: Frequent reappearances over time and space can indicate
   deliberate placement, even if identifiers change periodically.

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4.2.1.2.5.  Hardware Identity

   Analyzes available Bluetooth advertisement metadata, such as vendor-
   specific fields or Tag model indicators, while respecting identifier
   randomization.

   *Rationale*: Certain Tags (e.g., known commercial Tags) are more
   likely to be associated with tracking.  Even with rotating
   identifiers, consistent vendor metadata or other characteristics may
   provide useful signals.

4.2.1.2.6.  Environmental Context

   Considers the location in which the Tag is seen (e.g., home, office,
   public places).

   *Rationale*: Tags seen only in familiar, safe zones may be harmless.
   Appearances in unfamiliar or private locations without explanation
   raise concern.

4.2.1.3.  Location-tracking Tag Alerts

   Location-tracking Tags may be difficult to locate, and users may not
   have a Device that can actively or passively scan for Location-
   tracking Tags.  The DULT Protocol should be built with accessibility
   in mind (https://cdt.org/insights/centering-disability-in-mitigating-
   harms-of-bluetooth-tracking-technology/) so that the most people can
   be protected by the protocol.  In addition to push notifications on
   nearby Devices, Location-tracking Tags themselves should be able to
   notify end users.  This should include periodic sounds when away from
   all Tag Owners, along with lights and haptics so that people who are
   Deaf or hard of hearing can still locate them.  Tracking Tag Alerts
   should also educate the user on methods to successfully find and
   disable Tags (see Section 4.2.2 and Section 4.2.3).

4.2.1.4.  Crowdsourced Network Activities Logs

   Stephenson et al. (https://www.usenix.org/system/files/
   usenixsecurity23-stephenson-lessons.pdf) point out that Internet of
   Things devices like Location-tracking Accessories do not have ways to
   reveal abusive behavior.  This can be addressed through the use of
   detailed logs that provide insights for Victims about which accounts
   have accessed the location of which Accessories and when.
   Crowdsourced Networks should log common user activities for review by
   each Accessory Owner, and should not be able to be easily deleted by
   Accessory Owners, who might do so as a way to hide evidence of
   Unwanted Tracking.

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   Logs should include sufficient detail to detect Unwanted Tracking
   without being another vector for surveillance.  For example, a log
   could state that "User B viewed the location of Accessory X at
   [time]."  By including information about user, Accessory, and time,
   Victims can determine whether their own Accessories are being used to
   track them, and whether or not their accounts connected to the
   Crowdsourced Network are compromised.

4.2.2.  Finding Tracking Tags

   Even after a Tag is detected through passive or active scanning, a
   user may have difficulty in locating it.  For example, a Tag may be
   buried under a vehicle cushion.  Platforms should allow users who
   have discovered a Tag through passive or active scanning to request
   that the Tag signal its presence.  This assistance should be done in
   a way that is accessible to users with sensory or other impairments
   by using multimodal signals as described in Section 4.2.1.3.
   Manufacturers/Platforms may also implement other methods to assist in
   locating Tags, such as precision finding using Ultra-wideband.

4.2.2.1.  Lost Mode

   Some Platforms allow Accessories to be marked as lost.  When another
   user finds the Accessory, they can view a message and/or contact
   information of the Accessory Owner.  While helpful in a benign case
   where an Accessory is truly lost, care must be taken to ensure that
   the lost mode function is not used for harassment.  Platforms should
   use a non-customizable lost message and display either Obfuscated
   Owner information, or a full phone number or email address if the
   Accessory Owner chooses to share that information.

4.2.3.  Disabling Tracking Tags

   In order to effectively prevent Unwanted Tracking, users should be
   able to disable Location-tracking Tags.  This includes a Non-Owner
   user being tracked by a Tag's Owner, as well as an Owner user who
   believes that an Attacker is using their own Tag to track them.
   Platforms should provide instructions for disabling Location-tracking
   Tags once they are located.  Manufactures/Platforms should also
   consider allowing Location-tracking Tags to be disabled remotely.

   Beyond simple deactivation, users should also receive guidance on
   additional steps they may take, depending on their specific
   situation:

   *  Advice on destruction or preservation: In some cases, destroying a
      Tag may eliminate the risk of further tracking.  However, users
      should be made aware that doing so may result in the loss of

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      evidence that could otherwise be used to prove tracking or
      identify an abuser.  Destroying the Tag might also lead to
      escalation in abusive contexts.  Guidance should help users weigh
      these risks and determine the most appropriate course of action.

   *  Serial number access and use: Platforms should inform users how to
      retrieve the serial number or unique identifier of the Tag, even
      if the Tag is not from the same Platform.  Serial numbers may be
      used to report the Tag, verify its origin, or, in cooperation with
      manufacturers or authorities, identify the registered Owner(s) of
      the Tag.

   It is important to consider where educational and disabling guidance
   is hosted.  For instance, information about disabling Tags should be
   publicly accessible, possibly from neutral, decentralized, or
   international organizations, to mitigate the risk of government
   censorship or politically motivated takedowns.  This ensures access
   for vulnerable users, including those in high-risk environments or
   authoritarian regions.

4.2.4.  Notification Management for Trusted Accessories

   To reduce alert fatigue and improve user experience, implementations
   should allow users to snooze passive notifications from Location-
   tracking Tags that have been explicitly marked as trusted or
   friendly.  This is particularly useful in scenarios where users
   regularly encounter the same Tag (e.g., a family member's keys or a
   shared vehicle Tag).

   Such snoozed Tags may also be de-prioritized or grouped separately
   during active scans, helping users focus on unfamiliar or potentially
   malicious Tags.  Platforms should make it easy to manage snoozed Tags
   and review or revoke trust status as needed.  It is also advisable to
   implement revalidation mechanisms, for example, resuming
   notifications after a period of time to prevent long-term blind
   spots.

   Some Platforms may wish to implement family sharing or shared
   Ownership models, where multiple users can be associated with a
   single Tag. However, this introduces the risk of abuse (e.g., an
   Attacker adding a Target to the shared list in order to avoid
   triggering passive notifications), and therefore should be approached
   with caution and abuse mitigation in mind.  These features are
   optional and may vary by Platform.  Whenever shared Ownership is
   used, information about all Owners should be made available when a
   Tag is suspected of Unwanted Tracking (see Section 4.2.1.2).

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4.3.  Design Constraints

   There are also design constraints that the DULT Protocol must
   consider, including limitations of the Bluetooth Low Energy (BLE)
   protocol, power constraints, and Device constraints.

4.3.1.  Bluetooth constraints

   Detecting Tags requires analyzing Bluetooth Low Energy (BLE)
   advertisement packets.  Advertisements are publicly transmitted,
   allowing passive scanning by any nearby receiver.  While this enables
   open detection of unknown Tags, it also raises privacy concerns (see
   Section 1).  Some BLE implementations employ randomized MAC addresses
   and other privacy-preserving techniques, which could impact
   persistent tracking detection.

   The BLE payload in BLE 4.0 can support advertisement packets of up to
   37 bytes.  One current adoption of Unwanted Tracking detection
   requires 12 of these bytes for implementing the basic protocol, with
   the remaining optional (see
   [I-D.detecting-unwanted-location-trackers]).  Implementation of the
   DULT Protocol will need to consider these limitations.  For example,
   in Eldridge et al (https://eprint.iacr.org/2023/1332.pdf),
   implementing Multi-Dealer Secret Sharing required using two
   advertisement packets were needed instead of one due to payload
   constraints.  While BLE 5.0 supports 255+ bytes of data, the protocol
   is not backwards compatible and thus may not be suitable for the DULT
   Protocol.

   BLE advertisements operate in the 2.4 GHz ISM band, making them
   susceptible to interference from Wi-Fi, microwave ovens, and other
   wireless devices.  The presence of environmental noise may degrade
   detection accuracy and introduce variability in scan results.

   BLE uses channel hopping for advertising (three advertising
   channels).  Scanners need to cover all these channels to avoid
   missing advertisements.  The BLE protocol also enforces strict power
   efficiency mechanisms, such as advertising intervals and connection
   event scheduling, which impact detection frequency.  Devices
   operating in low-power modes or sleep modes may significantly reduce
   their advertisement frequency to conserve energy, making periodic
   detection less reliable.  Furthermore, Platform-level constraints,
   such as OS-imposed scanning limits and background activity
   restrictions, further impact the consistency and responsiveness of
   tracking detection mechanisms.  For further discussion of power
   constraints, see Section 4.3.2.

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   Additionally, Bluetooth-based tracking systems typically rely on an
   active Bluetooth connection on the Owner’s Device to determine
   whether a Tag is in the Owner's possession.  If the Owner disables
   Bluetooth on their phone, the system may incorrectly infer that the
   Tag is no longer nearby, potentially triggering a false positive
   alert for Unwanted Tracking.  This limitation arises from the
   inability of Bluetooth-based systems to verify proximity without
   active signals from the Owner’s Device.  There is currently no
   straightforward solution to this issue using Bluetooth alone, and it
   represents an inherent trade-off between privacy and detection
   reliability.  Systems should account for this possibility and
   communicate it clearly to users.

   To address these challenges, detection mechanisms must balance
   efficiency, privacy, and accuracy while working within the
   constraints of the BLE protocol.  Solutions may include leveraging
   multiple observations over time, integrating probabilistic risk
   scoring, and optimizing scanning strategies based on known BLE
   limitations.

4.3.2.  Power constraints

   Unwanted tracking detection mechanisms typically rely on periodic
   Bluetooth scanning to identify unknown Accessories.  However,
   continuous background scanning poses a significant power challenge,
   especially for mobile Devices with limited battery capacity.
   Maintaining high-frequency scans for extended periods can lead to
   excessive energy consumption, impacting Device usability and battery
   longevity.

   To address these concerns, detection systems must incorporate power-
   efficient approaches that balance security with practicality.
   Adaptive scanning strategies can dynamically adjust the scan
   frequency based on contextual risk levels.  For example, if a
   suspicious Accessory is detected nearby, the system can temporarily
   increase scan frequency while reverting to a lower-power mode when no
   threats are present.

   Event-triggered detection offers another alternative by activating
   scanning only in specific high-risk scenarios.  Users moving into a
   new location or transitioning from a prolonged stationary state may
   require more frequent detection, while routine movement in known safe
   environments can minimize energy consumption.

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   The DULT Protocol must account for these power limitations in its
   design, ensuring that detection mechanisms remain effective without
   significantly degrading battery performance.  Consideration of
   Device-specific constraints, such as variations in power efficiency
   across smartphones, wearables, and IoT devices, will be critical in
   maintaining a balance between security and usability.

4.3.3.  Device constraints

   Unwanted tracking detection is constrained by the diverse range of
   Devices used for scanning, each with varying hardware capabilities,
   operating system restrictions, processing power, and connectivity
   limitations.  These factors directly impact the effectiveness of
   detection mechanisms and must be carefully considered in protocol
   design.

   Hardware variability affects detection accuracy.  While newer
   smartphones are equipped with advanced Bluetooth Low Energy (BLE)
   chipsets capable of frequent and reliable scanning, older
   smartphones, feature phones, and IoT devices may have reduced BLE
   performance.  Differences in antenna sensitivity, chipset power, and
   OS-level access control can result in inconsistent detection, where
   some Devices fail to detect tracking signals as reliably as others.

   Operating system restrictions can affect detection efforts,
   particularly due to background Bluetooth Low Energy (BLE) scanning
   policies.  Both iOS and Android implement mechanisms to manage
   background scanning behavior, balancing energy efficiency and privacy
   considerations.  On iOS, background BLE scanning operates with
   periodic constraints, which may limit the frequency of detection
   updates.  Android applies similar policies to regulate background
   processes and optimize power consumption.  Additionally, privacy
   frameworks on mobile Platforms may influence how applications access
   and process certain Accessory-related data.  These factors, along
   with resource limitations in wearables and IoT Devices, can impact
   the feasibility of continuous scanning and detection.

   Further, Platform permission models can restrict access to BLE scan
   data.  For example, Android requires coarse or fine location
   permissions to perform BLE scanning, and users may revoke these
   permissions.  Additionally, radio coexistence (BLE and Wi-Fi sharing
   the 2.4 GHz band) can impact BLE performance, especially on Devices
   with shared chipsets.  User interface constraints, especially on
   wearables, may also limit how users receive or interact with tracking
   alerts.

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   Processing and memory constraints are another limiting factor,
   particularly for low-end mobile Devices and Tags.  Continuous
   scanning and anomaly detection algorithms, especially those relying
   on machine learning-based threat detection, require substantial
   processing power and RAM.  Devices with limited computational
   resources may struggle to maintain effective real-time detection
   without degrading overall performance.  Ensuring that detection
   mechanisms remain lightweight and optimized for constrained
   environments is essential.

   Connectivity limitations introduce additional challenges.  Some
   Unwanted Tracking detection mechanisms rely on cloud-based lookups to
   verify Tag identities and share threat intelligence.  However, users
   in offline environments, such as those in airplane mode, rural areas
   with limited connectivity, or secure facilities with network
   restrictions, may be unable to access these services.  In such cases,
   detection must rely on local scanning and offline heuristics rather
   than real-time cloud-based verification.

   To address these challenges, detection mechanisms should incorporate
   adaptive scanning strategies that adjust based on Device
   capabilities, optimizing performance while maintaining security.
   Lightweight detection methods, such as event-triggered scanning and
   passive Bluetooth listening, can improve efficiency on constrained
   Devices.  Additionally, fallback mechanisms should be implemented to
   provide at least partial detection functionality even when full-
   featured scanning is not available.  Ensuring that detection remains
   effective across diverse hardware and software environments is
   critical for broad user protection.

4.4.  Priorities for the DULT WG

   While all of the above design considerations should be considered,
   the following topics are considered highest priority for the
   technical documents of the DULT WG to address:

   *  Active Scanning

      -  The documents should ensure platforms implement active scanning
         for all DULT compliant Accessories.

   *  Passive Scanning

      -  The documents should ensure Accessories and Devices implement
         finding algorithms, issue Unwanted Tracking Alerts and
         otherwise notify users of Accessories in proximity, and allow
         users to manage Unwanted Tracking Alerts to improve detection
         of Unwanted Tracking and/or prevent alarm fatigue

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   *  Nonconformant Accessories

      -  The documents should consider how to minimize the ability of
         nonconformant Accessories to access the Crowdsourced Network

   *  Remote Disablement

      -  The documents should consider whether Remote Disablement of
         Accessories is feasible to implement in a way that cannot be
         used to compromise the Crowdsourced Network

   *  Crowdsourced Network Activities Logs

      -  The documents should provide guidance to platforms about how to
         implement activities logs to help Targets identify possible
         Unwanted Tracking

5.  IANA Considerations

   This document has no IANA actions.

6.  Normative References

   [I-D.detecting-unwanted-location-trackers]
              Ledvina, B., Eddinger, Z., Detwiler, B., and S. P.
              Polatkan, "Detecting Unwanted Location Trackers", Work in
              Progress, Internet-Draft, draft-detecting-unwanted-
              location-trackers-01, 20 December 2023,
              <https://datatracker.ietf.org/doc/html/draft-detecting-
              unwanted-location-trackers-01>.

   [I-D.draft-ietf-dult-accessory-protocol]
              Ledvina, B., Lazarov, D., Detwiler, B., and S. P.
              Polatkan, "Detecting Unwanted Location Trackers Accessory
              Protocol", Work in Progress, Internet-Draft, draft-ietf-
              dult-accessory-protocol-00, 3 November 2024,
              <https://datatracker.ietf.org/doc/html/draft-ietf-dult-
              accessory-protocol-00>.

   [I-D.draft-ietf-dult-finding]
              Fossaceca, C. and E. Rescorla, "Finding Tracking Tags",
              Work in Progress, Internet-Draft, draft-ietf-dult-finding-
              01, 6 June 2025, <https://datatracker.ietf.org/doc/html/
              draft-ietf-dult-finding-01>.

   [I-D.draft-ledvina-apple-google-unwanted-trackers]
              Ledvina, B., Eddinger, Z., Detwiler, B., and S. P.
              Polatkan, "Detecting Unwanted Location Trackers", Work in

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              Progress, Internet-Draft, draft-ledvina-apple-google-
              unwanted-trackers-02, 2 January 2026,
              <https://datatracker.ietf.org/doc/html/draft-ledvina-
              apple-google-unwanted-trackers-02>.

   [RFC2119]  Bradner, S., "Key words for use in RFCs to Indicate
              Requirement Levels", BCP 14, RFC 2119,
              DOI 10.17487/RFC2119, March 1997,
              <https://www.rfc-editor.org/rfc/rfc2119>.

   [RFC8174]  Leiba, B., "Ambiguity of Uppercase vs Lowercase in RFC
              2119 Key Words", BCP 14, RFC 8174, DOI 10.17487/RFC8174,
              May 2017, <https://www.rfc-editor.org/rfc/rfc8174>.

Acknowledgments

   Many thanks for feedback from Brent Ledvina, Barry Leiba, Michael
   Ricardson, Eric Rescorla, Christine Fossaceca, and Alexis Hancock,
   and for contributed text from Corbin Streett, Diana Appanna, and Eva
   Galperin.  We also gratefully acknowledge the guidance and support of
   the DULT Working Group Chairs, Erica Olsen and Sean Turner, and the
   Area Director, Deb Cooley, throughout the development of this
   document.

Authors' Addresses

   Maggie Delano
   Swarthmore College
   Email: mdelano1@swarthmore.edu

   Jessie Lowell
   National Network to End Domestic Violence
   Email: jlowell@nnedv.org

   Shailesh Prabhu
   Nokia
   Email: shailesh.prabhu@nokia.com

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