By owning the BIOS/EFI layer in their devices. But if I remember correctly, you can't use a Bluetooth keyboard when entering your FileVault password. One of the

By owning the BIOS/EFI layer in their devices. But if I remember correctly, you can't use a Bluetooth keyboard when entering your FileVault password. One of the many reasons why I never turn off my machine as I use it clamshell 99.9% of the time.