There is inherent 'manufacture' costs in anything. Be it electricity, a firmware flash, a digital movie whatever but its the choice of action which is the issue I think.
Bit of a dead horse we've all heard before but it seems if you try to force people/market into a direction by heavy restrictions and control, now more than ever I think you will be faced with a strong resistance. It's a losing battle. The only effective solution is to change to a more progressive business model. Theyre going about it bass ackwards and Zephyr's statement is a good indicator of that.
I think Louis CK's latest experiment is one good example of that in today's changing digital media distribution environment. (say that 10 times fast)