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why would tuners not be doing this on your behalf?! You are requesting them to do it for you, if that isn't delegation of authority (in this case acting on your behalf to tune) then what is? Any person (in this case the tuner) providing you with a service, that you requested, but are unable to complete by yourself is acting on your behalf as you have given them authority to do so and therefore would fall under the exception.
here is the exert:
Under the exemption as proposed, circumvention would be
allowed when undertaken by or on behalf of the lawful owner of the
vehicle.
Meaning as long as the tuner has authorization from yourself he IS acting on your behalf and therefore covered in the exemption (p.40)
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