Aside from Google, with its own Nexus phones, there's no guarantee that the other Android manufacturers will take such dramatic hardware measures, especially if it means sacrificing performance.
All of this fragmentation creates a potential headache for law enforcement. Should the FBI or another government body need help to tap an Android phone, the initial question will be — Who do we call?
It could be Google, a manufacturer or even the carrier, like AT&T or Verizon.
In the San Bernadino case, the FBI wants access to a specific device. But the discussion goes way beyond just gadgets and wades into the apps and services that are popularly used to communicate.
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For example, in the Paris attacks late last year, the terrorists were said to be chatting via WhatsApp and Telegram, often using encrypted communications.
Like Apple, app developers are setting out to protect consumer privacy, but the tradeoff with greater protection is that it makes law enforcement's job more challenging.
"It's a broader set of technological capabilities that we're all trying to implement to make computing more secure and safer," said Malcolm Harkins, chief information security officer at security software vendor Cylance. "As we do that you've got malicious individuals that are then using those capabilities to try and hide their communication."