The contactless payment ramen shop connection

Have you ever noticed that ramen shops in Japan kinda stick together? If there is one, there is another one close by, maybe two or three. And not just ramen shops, it can be Japanese sweets, eateries, anything. This might seem strange at first but there is a well known traditional Japanese business sense behind it. Two is better than one because more choices drives more foot traffic and interest. ‘Hey lets go to the local ramen shop district and get something to eat.’ The common interest is why store rivals tolerate each other because the increased customer interest and traffic drives business for everybody. All boats rise together.

I was reminded of this when a Japanese friend scolded me for constantly putting down code payments like PayPay when the speed and ease of Suica is so superior. “Why is it westerners always see things as black and white? Lots of choices drives interest right?” He was right of course. Coming from a western mindset it’s too easy to fall into the same old double standard of saying more choice is better on one hand, while on the other insisting that we should only use one thing. The old one size fits all, my choices are the best for everyone.

I also think there’s another, much larger and unacknowledged cultural difference regarding the concept of service: the Japanese mind tends to think of good service as being offered many options, while the western mind tends to think of good service as fulfilling one’s personal needs and wants of the moment. It may seem like a small difference but it’s a completely different way of seeing things. It’s also a good reminder that what’s convenient to our person is not necessarily convenient to other people.

One size doesn’t fit all. What’s the point of having all that different hardware when everybody’s forced to use the same software? Lots of choices for lots of people works better in the end…it drives interest in mobile payments when there are still a lot of people in Japan who have yes to use anything but plastic or cash. Variety invites and lifts all boats.

Pick one

Japan Cashless 2021: the Wireless Android NFC Reader Suck Index

You too can have the whole transaction world in your hands with the Android based Square Terminal for just ¥46,980

Now that contactless is everywhere, wireless contactless readers have become very fashionable and popular. Nobody wants wires or checkout lines. All of these systems are built around an Android based reading device connected to the internet payment service via Bluetooth, WiFi or 4G with a main terminal, an iPad or a laptop running payment network software. Convenient though they may be, compared with hard wired NFC reader performance they all suck with different levels of suckiness:

  1. stera: this lovely little ‘NFC antenna under the screen’ piece of shit from SMBC, GMO and Visa Japan is so slow that checkout staff put their hand over the stera screen/reader to keep customers waiting until the device is ready to go. This is followed by the instruction ‘don’t move your device until the reader beeps.’ It’s a 2~4 second wait until it beeps. This is 2014 era ‘you’re holding it wrong’ garbage nonsense. I teased one store manager about the hard wired JREM FeliCa readers that were swapped out with stera, “Those were too fast,” he said. Too fast?!
  2. PAYGATE: Another payment provider associated with GMO, slightly faster than stera but still slow, PAYGATE does’t like Apple Pay Suica•PASMO Express Transit very much. Have of the time it ignores it altogether forcing customers into the 2016 era ‘manually bring up Apple Pay Suica’ authenticate and pay maneuver. Another ‘you’re holding/doing it wrong,’ when the fault is on the checkout system side. Passé and totally unnecessary.
  3. AirPay: It’s weird that the cheap AirPay hardware performs better than PAYGATE or stera, it’s even weirder that AirPay performs better than Rakuten Pay which uses the very same reader but is stera shitshow slow.
  4. Square Terminal has gotten lots of media attention in Japan. Too early to experience it in the field yet but I’m not hopeful. Square Terminal is Android based after all and the NCF antenna under the screen design is the worst performing reader design out there. As one Brazilian reader wrote: “I just don’t like the ones running Android because at least here the software is less reliable and I managed to crash a few one by just taping my phone.”

Yep, that observation matches my experience. Payment network providers need better Android readers, the current crop is too slow getting the payment transaction ready to tap. In this era of endless subcontractor layers in the development process, creating a fast reliable Android based NFC wireless reader might be a tall order, if not impossible. The all over the place wireless NFC reader experience certainly doesn’t boast well for open loop advocates.

UPDATE
I ran across another crappy reader experience (above) and retweeted it. A reader had some questions about it, answered here by an anonymous expert. It basically comes down to poorly executed reader polling or not following Sony polling recommendations for FeliCa cards. This is what is happening in the above retweet. It is also what is going on with PAYGATE Station readers, half of the time the proper code hasn’t loaded correctly although this issue seems to be fixed in new PAYGATE Station checkout installations. Which brings us to the point I was trying to make: these performance issues can be fixed with reader firmware updates or transaction system software updates, but never are.

Wildcard polling involves the reader making a request for system code 0xFFFF and expecting the card/device to list all the system codes that it supports. Wildcard polling won’t work on an Apple Pay device in Express Transit mode – instead, the system code must be explicitly polled for (0x0003 for CJRC, 0x8008 for Octopus). You can cause Suica/Octopus to be automatically selected by sending SENSF_REQ (Polling command, 06) for those services explicitly.

I have verified that doing so with Apple Pay will cause the emulated card to be switched out as appropriate – the IDm value will also change, since Apple Pay emulates each card separately, instead of with a common IDm as with Osaifu Keitai. If you read the Sony documentation, you will see that developers are cautioned to also poll for the specific service codes they want to access if there’s no response to a wildcard poll.

Perhaps your reader doesn’t do this, but it’s fairly big omission…it should be doing explicit polling. Simply polling for service code 0x0003 should wake up Suica if selected as an Express Transit candidate, even if you don’t send any other commands. I’ve verified this with an RC-S380 reader and NFCPay.

Contactless Payment Turf Wars: EMV closed loop transit dumb cards

  1. Contactless Payment Turf Wars: Transit Platforms
  2. Contactless Payment Turf Wars: PiTaPa Pitfalls
  3. Contactless Payment Turf Wars: Why Oyster is missing from mobile
  4. Contactless Payment Turf Wars: Tapping the potential of TAP
  5. Contactless Payment Turf Wars: Apple Card and the Prepaid Innovation of Apple Pay Suica
  6. >Contactless Payment Turf Wars: EMV closed loop transit dumb cards

Prepaid transit smart cards are micro bank accounts on a card. What started as plastic in the mid 1990’s first transitioned to the cloud based mobile digital card era with Mobile Suica in 2006. Transit cards on mobile digital wallets are much more powerful and malleable than their plastic forebears, and occupy a coveted position in the mobile payments market. Credit card companies and banks spend enormous resources and effort to capture this transit fare business.

Background
Many smart cards use FeliCa and MIFARE. The technology has been on the market since 1994 and one of the reasons for platform popularity and longevity are the rich application development environments they offer (Calypso is also popular but limited to transit applications).

Developers can design a card architecture as ‘smart’ (like Suica) or as ‘dumb’ (like iD) but they are all smart cards because they contain an IC chip. In Japan FeliCa powers not only company ID cards, but also transit cards (Suica, PASMO, etc.), bank payment cards (iD, QUICPay) and rechargeable prepaid eMoney cards that anybody can buy and recharge at convenience stores (WAON, nanaco, Edy). Mobile FeliCa has been in place since 2004.

Smart/Dumb card architecture depends on use case, system processing cost efficiency and need. In a transit fare system, a dumb card use case is slower centralized processing, like waiting at the store checkout for card verification to clear. A transit smart card use case is instant locally processed stored value to keep people moving through the gates because centralized processing isn’t up to the task. This is why transit cards have used the stored value local processing model…until now.

Open Loop 1.0
EMV contactless credit cards arrived on the payments scene starting in 2007 but uptake was slow. Since EMV contactless uses the same NFC A as MIFARE based transit cards, the big EMVCo members (VISA, Mastercard, American Express) came up with a great marketing idea: use EMV contactless credit cards as a transit card. Thus EMV open loop transit was born.

EMV Open Loop 1.0 transit that debuted on Transport for London (TfL) Oyster system in 2014 filled mutual needs for TfL and bank card companies. Despite the success of Oyster, TfL wanted to reduce plastic card issue and management costs:

The current Oyster system, though very popular, is expensive and complex to administer. Contactless bank cards use existing technology, responsibility for issuing cards would lie with the banks rather than TfL, and the operating costs should be lower.

The Future of Ticketing London Assembly (2011)

In 2017 there was a push to nudge people away from their Oyster cards and towards contactless. One announcement rang out all over London’s tube stations: Why not use your contactless bank card today? Never top up again, and it’s the same fare as Oyster.

How Long Does The Oyster Card Have Left? Londonist (2018)

Using bank cards in place of MIFARE Oyster cards accomplished that and because MIFARE was late to the mobile party TfL management decided decided their mobile strategy would be Apple Pay and Android Pay EMV card support. Meanwhile the bank card companies captured transaction fees from mundane transit fares at the gate, got the benefit of using the float instead of TfL, and got people into the habit of using credit cards for tiny purchase amounts. Our parents thought buying coffee with a credit card instead of small change was ridiculous because credit cards were reserved for ‘serious purchases’. Not anymore.

TfL Open Loop was judged a big success and got rave reviews from tech journalists around the world who hailed it as the future of transit ticketing: time to dump those proprietary transit smart cards and go all in with ‘open standard’ EMV open loop if you want the latest and greatest transit fare system. This gave transit agencies and the governments that run them the wrong idea that EMV is a cure all transit fare system solution.

1.0 shortcomings
The problem is that EMV is not an open standard, it is owned and managed by the proprietary EMVCo that is wholly owned by the major credit card companies. EMV is a ‘one size fits all’ payments technology created for the needs of credit card companies and banks. It was never designed as a transit fare solution and will never evolve to incorporate transit needs. Experts agree:

A universal truth is that each transport market is highly unique. While EMV may be the best solution for some, the reality is that a standardized deployment of this model is not best suited to everyone.

Transit systems shouldn’t confuse open loop pay with EMV

The U.S. has been a tough market for transit agencies to deliver successful open-loop systems into, as banks have not been in step with these ambitions.

Is now the time for open-loop transit in the United States?

There is no escaping the basic reality that EMV is a slow dumb smart card. It works well for what it was designed for: store purchases where card transaction latency is not a problem while the checkout terminal communicates with the bank system that has your account information.

Transit fare systems don’t have your bank account information on file, and there are limits with what the backend transit fare system can do when an anonymous bank card number appears on gate reader where long transaction latency is unacceptable. There are tradeoffs: the card gets verified but the transit bill gets settled long after the transit. This is why EMV open loop 1.0 only works for simple or flat fare structures. The result was a 2 layer fare system on London Oyster, Sydney Opal and Chicago Ventra:

  • Plastic and digital EMV open loop dumb card with basic fare transit for users with approved bank cards
  • Plastic transit MIFARE smart cards covering all fares including special fare discounts, commuter passes, etc., for everybody else

Oyster, Opal and Ventra wanted to add mobile support across the board but this meant supporting EMV and MIFARE. All of these are managed by Cubic Transportation Systems who worked with the bank card companies and came up with a new product to solve the dilemma: EMV closed loop transit dumb cards.

Open Loop 2.0
Apple Pay Ventra is this new EMV closed loop mobile transit card product, the launch gave us a first glimpse of the 3 layer fare system:

  • Plastic and digital EMV open loop dumb cards with basic fare transit for users with approved bank cards
  • Digital EMV closed loop dumb cards that cover regular fares and commute passes with special fares to be added later
  • Legacy plastic MIFARE transit cards for everybody else

It’s still a mixed EMV and MIFARE environment but MIFARE is limited to legacy plastic transit cards that can be bought with cash at station kiosks. But we can be sure that MIFARE will be phased out at some point.

The Apple Pay Ventra model is being used for digital Opal trials on Apple Pay and Samsung Pay, and is on tap for digital Oyster and digital OMNY. A basic outline:

  • The transit card is actually a EMV Mastercard prepaid debit card issued by 3rd party bank
  • The Mastercard as transit card is ‘closed loop’ and can only be used for transit and nothing else
  • The user must create an account to use the digital card. The transit account and prepaid/debit information is centralized and managed by the card issuer, nothing is stored value
  • All digital transit card management and housekeeping (adding or transferring cards, recharge, checking the balance, etc.) must be done in a separate app (Ventra App, Opal App, etc.), nothing can be done directly in Wallet
  • Express Transit is not part of the native EMV card architecture and has to be added as part of broader open loop support on the backend fare system by the operator and Apple, this is why Express Transit is missing in the initial test phase of digital Opal: the current Opal fare system does not support it

As this is an EMV bank card dressed up as a transit card, it is still limited by EMV card architecture and bank card network protocol. In place of local stored value it uses the bank card account model. On mobile this means all card housekeeping is in the app, users can’t create, transfer or recharge transit cards directly in Wallet like Suica, PASMO, SmarTrip or TAP. Direct reload/recharge in Wallet is not supported because the EMV format itself does not support local stored value. Apple Watch users can’t recharge EMV transit cards without the iPhone app. And like all cloud dependent services everything stops when networks goes down.

Mobile Suica does an excellent job of balancing and combining the strengths of local processed stored value performance, usability and reliability with the power of cloud attached services. It’s the gold standard of what a transit payment platform on mobile can achieve: leveraging transit card micro accounts to attach services and build business instead of giving it away to banks. Digital Opal testers familiar with Suica notice the difference and missing features:

Open Loop 3.0?
For centralized cloud proponents, including Junya Suzuki, the ultimate dream is having one cloud based account using facial recognition for all payment and transit needs. Cubic and centralized account proponents are already looking to speed up London transit gates beyond slow EMV card technology with barrier free face recognition transit gates:

according to CUBIC…their ‘fastrack gateless gateline’ concept, which is currently conducting small user testing, eliminates physical barriers to form an extended corridor-like gateway that between 65 and 75 users can walk through in a minute, whilst their faces are being scanned and synced for payment with their smartphones

Facial recognition to be your future ticket on the London Underground

The joke here is that, (1) JR East achieved those over 60 people per minute walk through levels with FeliCa based Suica cards and open barrier transit gates long ago, (2) the COVID face mask era is a huge challenge for face recognition systems, (3) Touchless transit, Express Transit on steroids, is already in the works.

Personally I think the Ultra Wideband Touchless approach that leverages personal biometric authentication from the user’s smartphone secure enclave instead of having it hosted on somebody else’s cloud system is the safer and more practical way to go. Privacy advocates will agree.

Speed is safety
Tap speed matters more than even in the COVID era

The next installment of the Contactless Payment Turf Wars
If nothing else closed loop EMV transit dumb cards reveal how bankrupt the ‘open loop is open’ argument really is. All Cubic and the card companies did was swap MIFARE for EMV, neither of which are open. And tap speeds are slower than ever with EMV the supermarket checkout protocol, so now we need Face ID transit gates to speed things up.

It’s fake debate. The real debate is online centralization for fare processing where everybody is forced to have a mobile account whether they need it or want it or not. And once everybody is forced to have an account to use transit the next step is forcing facial recognition.

The short term lesson here is that when transit agencies let banks and card companies run the transit fare concession they will never be free of them: there’s too much private money to be made off of running the backend services attached to public infrastructure. The long term lesson is that the mobile digital wallet solutions for Ventra, Opal, Oyster and OMNY are not about transit user convenience and all about convenience for misguided transit operators and their subcontractors.


Reader Questions
Instead of answering questions or comments via Twitter etc., I’ll answer here for the benefit of all readers.

Q: Not being able to recharge within Apple Pay has nothing to do with EMV vs. stored value though, right? If anything, that should be easier (just move money between accounts).

A: It’s true that MIFARE stored value transit cards such as HOP Fastpass force users to recharge via the app. The point of the piece is that EMV transit card features are defined by the EMV format, bank card protocols and how it’s all implemented on digital wallet platforms. In short, bank issuers control the feature set on the backend. I have yet to see a recharge button on any EMV prepaid card in Apple Pay Wallet, I suspect we’ll always see most operations limited to bank issuer apps, even for transit.

C: The open loathing of banks and credit card companies is honestly quite nauseating (but understandable, considering what Japanese banks are like, apart from the credit card companies).

A: Banks and card companies have an important place in transit, but card company ‘one size solves all’ open loop marketing is misleading and profitable mischief. A good transit fare system is all about balance, flexibility and incorporating innovation such as mobile wallets, for the benefit of transit users and safe operations. Bank cards for example are a wonderfully convenient recharge backend, this is where they shine and add real value to the transit user experience.

But swapping out a native transit fare system with an outsourced bank card account system and tech package that the transit company doesn’t ‘own’ is asking for trouble. How much is the long term cost when it doesn’t solve everything as promised? Who really benefits: the transit user, the transit company, or the system partners and consultants?

These are the questions I think people should be asking and discussing. Hopefully my posts outline the issues clearly so people can discuss them to find the best fit long term solution based on local transit region conditions.

C: Looks like Apple/Google Pay presents the card as a debit card to eligible terminals, which would explain why physical cards can’t be used in their current form.

A: Yes the NSW Transport Minister calls it ‘cross-pollinating platforms”: NSW government set to announce the trial on Tuesday, which will begin mid-year and run until December. Commuters will be able to pay for Uber, Lime Bike, Ingogo Taxi or Manly Fast Ferry with their digital Opal card.

Apple Pay Ventra: the closed loop EMV card

Apple Pay Ventra finally launched October 26, 2020, a very long wait after the March 25, 2019 Apple Event announcement. I wrote about the delay blaming it on open loop when the Washington SmarTrip and LA TAP cards landed on Apple Pay first.

Ventra has a long glitchy open loop history from its debut with the ill-fated Mastercard debit Ventra. Streets Blog had this to say about it in 2017.

Arguably it’s a good thing that the Ventra prepaid debit card is going the way of the dinosaur. The debit card function debuted with a long list of fees that had the potential to siphon of much of the money stored on the card, including:

A $1.50 ATM withdrawal fee
A $2 fee to speak to someone about the retail debit account.
A $6.00 fee for closing out the debit balance
A $2 fee for a paper statement
A $2.95 fee to add money to the debit account using a personal credit card
A $10 per hour fee for “account research’’ to resolve account discrepancies

“These fees were probably not any different than other bank cards offered by Money Network or Meta Bank or other predatory banks,” says Streetsblog Chicago’s Steven Vance, who reported on the issue at the time. “But it was shameful for the CTA to be aligned with that.”

After a backlash, most of these fees were reduced or eliminated, but CTA retail outlets were still allowed to charge Ventra card holders a fee of up to $4.95 to load cash on the debit sides of their cards. So maybe it is for the best that the CTA is getting out of the bank card business.

StreetsBlog Chicago December 2017

Getting Ventra out of the bank card business is easier said than done when the whole system is designed around open loop. Mastercard stopped issuing Ventra branded prepaid debit cards in 2017 but they have managed Ventra account services all this time. The Ventra plastic card is MIFARE DESFire EV1 which fits the standard Cubic Transportation Systems management style: all of the various transit card systems they manage around the world were designed and built with MIFARE stored value cards at the core. These include Chicago Ventra, London Oyster, Sydney Opal, Washington SmarTrip, LA TAP, etc.

An Apple Pay Ventra Wallet screenshot from a Japanese Twitter user revealed a fascinating bit of information. Apple Pay transit cards like Suica, SmarTrip and TAP all show a stored value card balance. Apple Pay Ventra does not, it shows a card number like a Wallet credit card. This means Apple Pay Ventra is a reincarnated Mastercard prepaid debit card, but this time it’s disguised as a mobile transit card with Mastercard running card account services.

Apple Pay Ventra: the closed loop EMV transit card
Tech blog coverage of the Apple Pay Ventra launch only mentioned Express Transit but there are important limitations:

  1. Ventra Card on iPhone 6S and later / Apple Watch Series 1 and later, can only be used on the CTA and Pace bus services, but not Metra or Pace Paratransit. RTA and Student Reduced Fare cards, including U-Pass cards, and free ride Ventra Cards cannot be added to Apple Wallet yet. (from StreetsBlog Chicago)
  2. Direct reload/recharge in Wallet is not supported because the EMV format itself does not support local stored value. You have to reload the card in Ventra App. This really sucks for Apple Watch Ventra users. In the United States only Apple Pay TAP and Apple Pay SmarTrip support Wallet recharge, interestingly those systems are closed loop.

We have the following pieces: open loop, Cubic fare system management, Mastercard managed Ventra account services, MIFARE for plastic cards, EMV for mobile digital cards with a closed reload/recharge model that limits everything from card issue and recharge to Ventra App, and slow tap speeds.

The result is a centralized account processing mishmash of open loop and closed loop parts, ‘heavy’ in every performance aspect that pales in comparison to the local stored value process speed and flexibility of a user friendly Apple Pay Suica•PASMO that works across subway, bus and rail, for both fixed and distance fares.

The mishmash only works for CTA fixed fares and transit fare readers ‘live’ in the system. Distance based METRA fare are outside of the system with one time ticket purchases shown to the train conductor. Because everything is centralized account processing, all Ventra housekeeping must be done in the Ventra app unlike Apple Pay Suica•PASMO users who can live without an app or account: everything from recharge to card creation can be done in Wallet.

Simply put, Apple Pay Ventra is the digital rebirth of the problematic open loop based Mastercard Ventra prepaid debit card that is closed and only works on the Ventra system. The Sydney Opal card is about to enter digital wallet tests with Mastercard running the show with a similar set of Ventra pieces: Mastercard EMV issue for mobile, MIFARE plastic cards, Cubic management, etc. Expect similar results.

EMV transit cards: next installment of the Contactless Payment Turf Wars
If nothing else Apple Pay Ventra reveals how flimsy the ‘open loop is open’ argument really is: the Apple Pay Ventra prepaid debit card as transit card can only be used on the Ventra system. How open is that? All they did was swap MIFARE for EMV, neither of which are open standards. And tap speeds are slower than ever with EMV, aka the supermarket checkout protocol.

It’s fake debate. The real debate is online centralized fare processing where everybody is forced to have a mobile account whether they need it or want it or not, versus offline local fare processing where mobile accounts are optional. Guess which model delivers faster tap speeds while doing a better job of protecting your online privacy.

The lesson here is that when transit agencies let banks and card companies run the transit fare concession, they will never be free of them: there’s just too much private money to be made off of running the backend services attached to public infrastructure. And the bank card industry has no interest in improving their slow EMV supermarket checkout card spec for transit. Nobody in Sydney will bother asking who ends up getting the float interest from Opal cards when Mastercard runs the account backend. Card issuers like it that way.

The only question remaining is this: now that we know the Ventra EMV Mastercard prepaid debit card as mobile digital transit card is same one for mobile Opal…will it be the same for MTA mobile OMNY and TfL mobile Oyster? I suspect so: this is the new Cubic mobile transit card business model with NXP MIFARE the loser in this latest installment of the contactless payment turf wars.

UPDATE

A reader was kind enough to scan his Apple Pay Ventra card with a NFC tag reading app. Results confirmed what I outline above: Apple Pay Ventra is a EMV Mastercard prepaid debit disguised as a transit card. This officially marks a migration away from stored value MIFARE transit cards to stored in the cloud EMV prepaid debit cards for mobile digital transit card systems managed by Cubic.

Specifically it means the local stored value information that was held by the MIFARE plastic card has been migrated to an online Mastercard managed account for Apple Pay Ventra as the EMV credit card format wasn’t designed for local stored value. Just like the title says: Apple Pay Ventra is a closed open loop card.

We all float

The float is essentially double-counted money: a paid sum which, due to delays in processing, appears simultaneously in the accounts of the payer and the payee.

Individuals and companies alike can use float to their advantage, gaining time or earning interest before payment clears their bank.

Investopedia

One of the great tragedies of the NYC MTA is that it’s a too-much-public-not-enough-private transit cash pipe with too much exposure to local NY politics. NYT has a wonderful video on YouTube that explains the critical MTA flaw: politicians cleverly borrow against the MTA cash pipe for pork barrel projects that have little or nothing to do with MTA, but leave it highly leveraged and helpless to fix it’s own problems or invest in infrastructure.

Think of what MTA could really do if it was effectively protected from political interference, with full control of its own money and a Suica-like transit+payment empire, free to use the float of all those MetroCards soon to be OMNY transit cards.

One of the many things never discussed about open loop is who uses the float, but banks hold the money until the user account is settled with the transit company and they take a cut of the fare. It doesn’t take much imagination to see why banks and credit card companies really like promoting open loop.

Closed loop Japanese transit companies don’t talk about the float either but Japan IC Transit cards are like micro bank accounts with unused e-money balance and plastic card deposits sitting in all those Suica, PASMO, ICOCOA, manaca, etc. Japanese transit companies love to put all those micro bank accounts to work earning interest.

Japanese transit companies and Hong Kong Octopus have built those micro bank account transit cards into a very nice transit payment platform business that combines transit, payments and other services attached to the card which means there’s a lot more stored fare floating around than plain old transit-only cards. The addition of digital wallets like Apple Pay Suica and Apple Pay Octopus means there’s ever more e-money moving through those cards with short term parking…more float for transit companies to earn interest.

It’s a wonder why more transit companies haven’t followed the transit payment platform model to capture more business in the digital wallet era, but it’s testament to how little control they have over their own business destiny. Next time when you hear the praises of open loop over closed loop, remember to think about who’s floating in that business arrangement…and who’s not.