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In connection with their 2018 preliminary injunction motions, Plaintiffs presented considerable evidence that Georgia’s outdated DRE voting system is highly susceptible to manipulation and malfunction.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