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Rate limiting is implemented by a high quality secure element hardened against physical tampering. It isn't implemented by the regular SoC, RAM or the OS. It's not simple to bypass the throttling making a random 6 digit PIN secure.

GrapheneOS adds support for a strong passphrase to avoid depending on the secure element. It also adds the option to set a 2nd factor PIN for fingerprint unlock to make using a strong passphrase convenient via fingerprint+PIN secondary unlock while in After First Unlock state. Only 5 fingerprint unlock attempts are permitting and an incorrect 2nd factor PIN counts towards it so it's hardly a making the device protection weaker. Our PIN scrambling and the duress PIN features can also both be used with the 2nd factor PIN.

What if the supplier backdoors the secure element? It would be better to just encourage the user to use a high-entropy key, and not bother with the secure element at all.
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