The structural problem is that revenue goes to program costs and traffic calming, not to anyone harmed by speeding, which makes the fines punitive in character under any substance-over-label analysis.

The lack of DMV points and criminal record weakens the argument somewhat, but under California's substance-over-label approach those omissions aren't dispositive. They merely show the legislature knew how to stay on the civil side of the line, not necessarily that it succeeded.

If a court finds the penalties punitive in character, the owner-liability structure becomes a compounding problem: California's state due process protections are arguably more robust than federal, and imposing a punitive fine on a registered owner without proof they were driving, while burden-shifting exculpation to them looks increasingly difficult to sustain.

> These aren't niche services. They are the backbone of how major VPN and proxy providers operate.

> This isn't datacenter IP space being labeled as residential — it's actual ISP networks being leveraged as proxy pipes

The "this isn't X, it's Y" construction is a bright red tell for AI slop. Posting AI slop is just bad manners.

Places I have lived in: London, Santiago, Rio de Janeiro, Miami, New York, San Francisco.

RFE's and rejections don't cause problems by themselves. A denial can cause problems if the reason for denial is fraud or misrepresentation.