Is that real? I've heard it widely repeated but the NHTSA definitions very strongly suggest that this loophole doesn't actually exist:

> https://static.nhtsa.gov/odi/ffdd/sgo-2021-01/SGO-2021-01_Da...

The Reporting Entity’s report of the highest- level driving automation system engaged at any time during the period 30 seconds immediately prior to the commencement of the crash through the conclusion of the crash. Possible values: ADAS, ADS, “Unknown, see Narrative.”