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I've haven't been flashed once since we've had the adaptive LEDs but, on the odd occasion I've seen another BMW with them coming towards me, I've though 'wow!, they're bright' - not dazzling, just much brighter/whiter than normal halogens or Xenons
So, assuming that your self-leveling system is working properly, perhaps people are just seeing very bright headlights coming towards them, making the assumption that you're on full beam and flashing in the expectation that they're about to get dazzled...
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