Comment by dragonwriter

Not sure why you are appealing to the rule on terms that aren’t defined, since the actual question is whether or not thet consider the vendor of the software powering the device as an “operating system vendor” which is, in fact, defined in the law, and the answer there seems to be hinge on whether or not they think it is a general purpose compute device, which would seem almost certain to be no for a traffic light, and likely to be no (but more debatable and potentially variable from instance to instance) in the other cases you list.

> Particularly since they don't even have accounts or users as a common-sense member of the public would understand them?

Not sure what having accounts or users “as a common sense member if the public would understand them” is relevant to since, to the extent having a “user” is relevant in the law, it to is defined (albeit both counterintuitively and circularly) in the law, and having an “account” isn’t relevant to the law at all.