[osy]

Yes really. The lack of any working implementation in production systems is an issue (D-RTM + encrypted sessions), something that Apple has done in an equivalent threat model since the iPhone 11. You can argue that "insecure by design" doesn't apply because there is a secure design in the abstract but the fact that nobody has adopted it in 20 years says something about the design itself.

It's _also_ insecure by design because in every deployed implementation (including with PIN), it is S-RTM meaning that _any_ UEFI driver vuln will compromise your TPM key. Yes, any UEFI vulnerability in its countless vendor drivers, USB stack, network stack, etc.