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Canada declares Flipper Zero public enemy No. 1 in car-theft crackdown
(arstechnica.com)
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this post was submitted on 10 Feb 2024
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As he said, that only works if the device is on, which would be really odd in a car. I'm not aware of any that keep comms on in sleep, since those are typically high power draw.
There are various sleep modes and it looks like Bluetooth can be active during some of them.
https://learn.microsoft.com/en-us/windows-hardware/design/device-experiences/bluetooth-power-management-for-modern-standby-platforms