One of the strengths of Apple&#x27;s arguments is that they do not have software that the government is trying to compel them to provide. The government compelling the creative act of making this software is not something that has occurred under the All Writs Act previously, as far as I am aware, so this would set precedent.<p>Once the software is already created, it is, at worst, just a question of getting the timing right for the next request in order to make such an order (to provide software to assist in the unlocking of phones) merely ordinary.<p>Aside from some arcana, what you are proposing is equivalent to the FBI&#x27;s position, which I think many here disagree with.