Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 33 of 153
to infiltration by new malware (or other modes of tampering with election
software or data) that can then contaminate the entire election system. (Id.)
C.
The DRE/GEMS system is particularly susceptible to
manipulation and malfunction.
In connection with their 2018 preliminary injunction motions, Plaintiffs
presented considerable evidence that Georgia’s outdated DRE voting system is
highly susceptible to manipulation and malfunction. As Plaintiffs’ expert, Dr.
Alex Halderman testified here (and most recently before the U.S. Senate Select
Committee on Intelligence), Georgia’s DRES are vulnerable to various routes of
infection and attack that are difficult or impossible to detect or reverse.
(Halderman Decl., Doc. 260-2.) They include the following: A computer virus
could subtly steal votes from one candidate and assign them to another, without
detection. A malicious intruder could install malware that would alter the vote
count or stop the machine from accepting votes, as demonstrated during the
2018 injunction hearing.30 Anyone with access to a single voter access memory
card, could spread malware from the card to DREs and then from DREs to the
election management system, potentially infecting the entire voting system. An
attacker can access the ballot programming files on an unsecure election
management system and piggyback on the pre-election programming process to
spread malicious software to the voting machines across all jurisdictions serviced
by the GEMS system.
And as Dr. Halderman demonstrated in April 2018,
There was no means of detection of this as the “malware modified all of the vote records, audit
logs, and protective counters stored by the machine, so that even careful forensic examination of
the files would find nothing amiss.” (Halderman Decl. ¶ 19, Doc. 260-2.)
30
33
Select target paragraph3
Connect to a paragraph
Connect to an entity
Disable highlights
Add to table of contents