(Edit: Not sure why this is being downvoted, accidental 911 calls have been enough of a strain that some cities have introduced fines for repeat offenders. SOS has increased these incidents even further.)

Intentional as well as repeated "mistake" calls.

There's a threshold for when it becomes problematic for emergency responders, so don't doubt that action will be taken at some point on these. (take a look at Port St. Lucie as an example of this). But this also makes me think the FCC might go after Apple on this one when it does get to that point.

The United States, and the severity is dependent on state and local agency. You will get fines for false alarms in many cases…so my question is, who would be ultimately liable?

(It’s a court based question so more rhetorical here)

(Edit: for those downvoting, take a look at Port St. Lucie who has introduced fines for repeated MISTAKE calls. And this was before the problem of SOS mode which has increased the strain of mistake calls)

The question really becomes, who is liable for associated fees with unnecessary calls? The phone's owner? Or Apple?

Misleading but not confusing. They’re used to falling for scams