Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 26 of 153 database at the State level, the ballot database is transmitted to the Counties, and then transferred onto memory cards that load the ballots into the DRE voting machines. At the end of the election, the election data from the memory cards is then uploaded onto the County GEMS server that tabulates the county election votes.24 Thus, in addition to serving as the ballot building platform, the GEMS system also serves as a means of communication/transmission of ballot and voting data downloaded to and from the DREs and between the County and State GEMS servers. Because of the interface between the GEMS and the DREs, an infection or intrusion in the GEMS system ballot programming files can spread viruses and malware from the GEMS to all voting machines serviced by GEMS. (See Halderman Decl. ¶ 31.) As described below, a malware or virus attack can occur at any level here (the ballot programming files, DRE removable memory cards, or GEMS database at the County or State level.) (Id. at ¶ ¶30-32.) The testimony of CES Director Michael Barnes about the GEMS system has been inconsistent. At the September 2018 injunction hearing he testified that, “[w]e have an air gapped system within the Secretary of State’s office that holds our ballot-building information, our ballot-building software. And that is the Until the November 2018 election, the SOS allowed county elections offices to transmit their election night results by modem to the state election night server. According to the Election Supervisor for Morgan County, called as a witness by Defendants, the current established state protocol she follows on election night for transmission of County returns instead of the modem transmission is to (1) copy on a flash drive the GEMS election results datafile; (2) take that drive to her internet connected computer; and (3) upload the GEMS vote tabulation results to the Election Night Reporting website run via PCC for the SOS. (Tr., Doc. 571 at 326.) The Georgia State Patrol transports the final CD containing the GEMS database election results from each county back to the SOS some days later, after the County Board of Elections has certified the vote totals. 24 26

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