Elections: Further Testing Could Provide Increased but Not	 
Absolute Assurance That Voting Systems Did Not Cause Undervotes  
in Florida's 13th Congressional District (02-OCT-07, GAO-08-97T).
                                                                 
In November 2006, about 18,000 undervotes were reported in	 
Sarasota County in the race for Florida's 13th Congressional	 
District (FL-13). After the contesting of the election results in
the House of Representatives, the task force unanimously voted to
seek GAO's assistance in determining whether the voting systems  
contributed to the large undervote in Sarasota County. GAO agreed
with the task force on an engagement plan, including the	 
following review objectives: (1) What voting systems were used in
Sarasota County and what processes governed their use? (2) What  
was the scope of the undervote in Sarasota County in the general 
election? (3) What tests were conducted on the voting systems in 
Sarasota County prior to the general election and what were the  
results of those tests? (4) Considering the voting systems tests 
conducted after the general election, are additional tests needed
to determine whether the voting systems contributed to the	 
undervote? To conduct its work, GAO met with officials from the  
State of Florida, Sarasota County, and Election Systems and	 
Software (ES&S)--the voting systems manufacturer--and reviewed	 
voting systems test documentation. GAO analyzed election data to 
characterize the undervote. On the basis of its assessments of	 
prior testing and other activities, GAO identified potential	 
additional tests for the Sarasota County voting systems.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-97T 					        
    ACCNO:   A76987						        
  TITLE:     Elections: Further Testing Could Provide Increased but   
Not Absolute Assurance That Voting Systems Did Not Cause	 
Undervotes in Florida's 13th Congressional District		 
     DATE:   10/02/2007 
  SUBJECT:   Calibration					 
	     Elections						 
	     Electronic equipment				 
	     Municipal governments				 
	     Product evaluation 				 
	     System software					 
	     System vulnerabilities				 
	     Systems testing					 
	     Voting						 
	     Voting records					 
	     Voting systems					 
	     ES&S Voting System 				 

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GAO-08-97T

   

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United States Government Accountability Office: GAO: 

Statement before the Task Force on Florida-13, Committee on House 
Administration, House of Representatives: 

For Release on Delivery: 
Expected at 4:00 p.m. EDT: 
Tuesday, October 2, 2007:  

Elections: 
Further Testing Could Provide Increased but Not Absolute Assurance That 
Voting Systems Did Not Cause Undervotes in Florida's 13th Congressional 
District:  

Statement of Dr. Nabajyoti Barkakati: Senior-Level Technologist: 
Applied Research and Methods:  

GAO-08-97T: 

GAO Highlights: 

Highlights of GAO-08-97T, a statement before the Task Force on Florida-
13, Committee on House Administration, House of Representatives.  

Why GAO Did This Study: 

In November 2006, about 18,000 undervotes were reported in Sarasota 
County in the race for Floridaï¿½s 13th Congressional District (FL-13). 
After the contesting of the election results in the House of 
Representatives, the task force unanimously voted to seek GAOï¿½s 
assistance in determining whether the voting systems contributed to the 
large undervote in Sarasota County. GAO agreed with the task force on 
an engagement plan, including the following review objectives: (1) What 
voting systems were used in Sarasota County and what processes governed 
their use? (2) What was the scope of the undervote in Sarasota County 
in the general election? (3) What tests were conducted on the voting 
systems in Sarasota County prior to the general election and what were 
the results of those tests? (4) Considering the voting systems tests 
conducted after the general election, are additional tests needed to 
determine whether the voting systems contributed to the undervote? To 
conduct its work, GAO met with officials from the State of Florida, 
Sarasota County, and Election Systems and Software (ES&S)ï¿½the voting 
systems manufacturerï¿½and reviewed voting systems test documentation. 
GAO analyzed election data to characterize the undervote. On the basis 
of its assessments of prior testing and other activities, GAO 
identified potential additional tests for the Sarasota County voting 
systems. 

What GAO Found: 

In the 2006 general election, Sarasota County used voting systems 
manufactured by ES&S, specifically iVotronic direct recording 
electronic (DRE) voting systems during early and election day voting 
and the Unity election management system, which handles the election 
administration functions, such as ballot design and election reporting. 

GAOï¿½s analysis of the 2006 general election data from Sarasota County 
did not identify any particular voting machines or machine 
characteristics that could have caused the large undervote in the FL-13 
race. The undervotes in Sarasota County were generally distributed 
across all machines and precincts. 

GAOï¿½s analysis found that some of the prior tests and reviews conducted 
by the State of Florida and Sarasota County provide assurance that 
certain components of the voting systems in Sarasota County functioned 
correctly, but they are not enough to provide reasonable assurance that 
the iVotronic DREs did not contribute to the undervote. Specifically, 
GAO found that assurance is lacking in three areas, and proposes that 
tests be conducted to address those areas. First, because there is 
insufficient assurance that the firmware in all the iVotronic DREs used 
in the election matched the certified version held by the Florida 
Division of Elections, GAO proposes that a firmware verification test 
be conducted on a representative sample of 115 (of the 1,499) machines 
that were used in the general election. Second, because an insufficient 
number of ways to select a candidate in the FL-13 race were tested, GAO 
proposes that a test be conducted to verify all 112 ways that GAO 
identified to select a candidate. Third, because no prior tests were 
identified that address the effect of a miscalibrated iVotronic DRE on 
the undervote, GAO proposes that an iVotronic DRE be deliberately 
miscalibrated to verify the accurate recording of ballots under these 
conditions. GAO expects these three tests would take 2 weeks, once the 
necessary arrangements are made. 

Should the task force ask GAO to conduct the proposed tests, several 
matters would need to be addressed before testing could begin, 
including obtaining access to the iVotronic DREs that have been subject 
to a sequestration order, arranging for a test site, obtaining some 
commercially available test tools, developing test protocols and 
detailed test procedures, and arranging for the video recording of the 
tests. Sarasota County election officials have indicated that they can 
help GAO access the machines and provide a test site between November 
26 and December 7, 2007. 

Although the proposed tests could help provide increased assurance, 
they would not provide absolute assurance that the iVotronic DREs did 
not cause the large undervote in Sarasota County. The successful 
conduct of the proposed tests could reduce the possibility that the 
voting systems caused the undervote and shift attention to the 
possibilities that the undervote was the result of intentional actions 
by voters or voters that did not properly cast their votes on the 
voting system. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://GAO-08-97T]. For more information, contact Keith 
Rhodes at (202) 512-412 or [email protected], or Naba Barkakati at (202) 
512-4499 or [email protected]. 

[End of section]  

Mr. Chairman and Members of the Task Force: 

I am pleased to appear before the task force today to present the 
findings on our review of voting equipment used in Florida's 13th 
Congressional District (Florida-13), which we are conducting in 
response to your request of May 25, 2007. 

In November 2006, about 18,000 undervotes were reported in Sarasota 
County in the race for Florida's 13th Congressional District.[Footnote 
1] Following the contesting of the election results in the House of 
Representatives, the task force met and unanimously voted to seek GAO's 
assistance in determining whether the voting systems contributed to the 
large undervote in Sarasota County. On June 14, 2007, we met with the 
task force and agreed upon an engagement plan, which included the 
following review objectives: (1) What voting systems and equipment were 
used in Sarasota County and what processes governed their use? (2) What 
was the scope of the undervote in Sarasota County in the general 
election? (3) To what extent were tests conducted on the voting systems 
in Sarasota County prior to the general election and what were the 
results of those tests? (4) Considering the tests that were conducted 
on the voting systems from Sarasota County after the general election, 
are additional tests needed to determine whether the voting systems 
contributed to the undervote? 

To conduct our work, we met with officials from the Sarasota County 
Supervisor of Elections, the Florida Department of State and Division 
of Elections, and Election Systems and Software (ES&S), the 
manufacturer of the voting systems used in Sarasota County. We reviewed 
voting system documentation, including standards documents, audit and 
testing documentation, submissions from the contestant and contestee, 
and selected Florida election laws and rules. In Sarasota County, 
election officials demonstrated how the ES&S voting system was used to 
support the 2006 general election. To determine the scope of the 
undervote in Sarasota County, we collected election data from the 
Supervisor of Elections and analyzed it to determine whether the 
undervote could be attributed to particular voting machines or machine 
characteristics. Specifically, we examined ballot image logs and event 
logs from the voting systems and technician and incident reports 
generated by elections staff from Sarasota County on election day. We 
also conducted various statistical analyses to characterize the 
undervote and to identify whether a subset of machines or precincts may 
have caused the large undervote. 

We reviewed test documentation and interviewed officials involved with 
testing from ES&S, the Florida Division of Elections, and the Sarasota 
County Supervisor of Elections. To determine the need for additional 
tests, we also reviewed the tests conducted following the election, 
including those conducted or sponsored by the Florida Division of 
Elections, including the parallel testing, the examination of Sarasota 
County's election procedures and practices, and the source code review 
conducted at Florida State University's Security and Assurance in 
Information Technology (SAIT) laboratory. We reviewed the final reports 
of these tests and also met with the leader of the source code review 
team. Following the agreement to and execution of a non-disclosure 
agreement with the Florida Department of State and ES&S, we obtained 
access to the iVotronic source code and reviewed it to further our 
understanding of the system and to verify some of the source code 
review's findings. We analyzed the available information and identified 
a key set of voting system objectives that, if implemented properly, 
would provide reasonable assurance that the voting systems did not 
malfunction and cause the large undervote in Sarasota County. Using 
these objectives, we used the results of testing previously conducted 
and assessed the extent to which these key voting system objectives 
could be met. For those objectives that could not be adequately 
assured, we assessed the significance of those objectives and 
identified tests that could be conducted to help try to assure those 
key voting system objectives were met. For each test, we identified 
resources that would be required, including time and manpower. 

We provided a draft of this report to the Florida Department of State, 
ES&S, and the Sarasota County Supervisor of Elections for their review 
and comments. The Florida Department of State and ES&S also conducted a 
sensitivity review to ensure that business proprietary information is 
not disclosed in this statement. 

We conducted our work from June to September 2007 in Washington, D.C.; 
Tallahassee and Sarasota, Florida; and Omaha, Nebraska. 

Results in Brief: 

In the 2006 general election, Sarasota County used voting systems 
manufactured by ES&S, specifically iVotronic direct recording 
electronic (DRE) voting systems during early and election day voting 
and the Unity election management system, which handles the election 
administration functions, such as ballot design and election reporting. 

Our independent analysis of the 2006 general election data from 
Sarasota County confirmed the large undervote in the race for Florida's 
13th Congressional District, but did not identify any particular voting 
machines or machine characteristics that could have caused the large 
undervote in the election. The undervotes in Sarasota County for the 
congressional race were generally distributed across all machines and 
precincts. 

We found that some of the prior tests and reviews provide assurance 
that the voting systems in Sarasota County functioned correctly, but 
they are not enough to provide reasonable assurance that the iVotronic 
DRE voting systems did not contribute to the undervote. For example, 
prior reviews provide reasonable assurance that the Unity election 
management system did not contribute to the undervote, and the votes 
captured by iVotronic DREs at the precincts match the voter count from 
precinct records within acceptable margins of error. 

Portions of the Florida state audit, such as the firmware comparison 
and parallel tests, provided useful information, but the results could 
not be applied to all the iVotronic DREs used in the election because 
the number of machines tested was too small. Additionally, the machines 
were not tested for all different ways a voter can select a candidate 
in the congressional race. We also did not find any prior testing that 
would help us understand the effects of a miscalibrated touch screen. 
To address these issues, we propose that (1) a firmware verification 
test, (2) a ballot test, and (3) a calibration test be conducted to try 
to obtain further assurance that the iVotronic DREs used in Sarasota 
County during the 2006 general election did not cause the undervote. 
The firmware verification test would compare the firmware in a 
representative sample of iVotronic DREs with the certified version of 
firmware. The ballot test would exercise 112 ways to select a candidate 
on 10 iVotronic DREs. The calibration test would deliberately 
miscalibrate an iVotronic DRE that uses the certified software and 
verify the functioning of the machine. We expect the testing would take 
2 weeks using a staff of about 6 to 8 people, once the necessary 
arrangements have been made. Although the proposed tests would provide 
increased assurance, they would not conclusively eliminate the machines 
as a cause of the undervote. 

Before commencing the testing, we would need to obtain access to the 
iVotronic DREs that have been subject to a sequestration order in the 
state court system of Florida, arrange for a test site, obtain some 
commercially available software and hardware for the firmware 
comparison test, develop test protocols and detailed test procedures, 
and arrange for video recording of the test. Sarasota County election 
officials have indicated that working around the county's election 
schedules, they could help us access the machines and provide a test 
site between November 26 and December 7, 2007. 

Our proposed tests could help reduce the possibility that the undervote 
was caused by the iVotronic DREs. However, even after completing the 
tests, we would not have absolute assurance that the iVotronic DREs did 
not play any role in the large undervote. Absolute assurance is 
impossible to achieve because we are unable to recreate the conditions 
of the election in which the undervote occurred. By successfully 
conducting the proposed tests, we could reduce the possibility that the 
iVotronic DREs were the cause of the undervote and shift attention to 
the possibilities that the undervote was the result of intentional 
actions by the voter or voters that did not properly cast their votes 
on the voting system. 

Draft copies of this statement were provided to the Secretary of State 
of Florida, the Supervisor of Elections of Sarasota County, and ES&S 
for their review and comment. The Florida Department of State provided 
technical comments, which we incorporated. The Sarasota County 
Supervisor of Elections did not provide us comments. 

In its comments, ES&S stated that it believes that the collective 
results of prior testing have demonstrated that the voting systems 
worked properly in Florida's 13th Congressional District race, and that 
the focus should be on testing the effect of the ballot display on the 
undervote. We disagree that the prior test results adequately 
demonstrate that the voting systems could not have contributed to the 
undervote. Our analysis identified three areas where further testing 
could provide increased assurance that the undervote was not caused by 
the voting systems. We agree with ES&S that the large undervote in 
Florida's 13th Congressional District race could have been caused by 
voters who intentionally undervoted or voters who did not properly cast 
their ballots, potentially because of issues related to the human 
interaction with the ballot. However, our review focused on whether the 
voting systems could have contributed to the large undervote. ES&S also 
provided technical comments, which we incorporated as appropriate. 

Background: 

The 13th Congressional District of Florida comprises DeSoto, Hardee, 
Sarasota, and parts of Charlotte and Manatee Counties. In the November 
2006 general election, there were two candidates in the race to 
represent the 13th Congressional District: Vern Buchanan, the 
Republican candidate, and Christine Jennings, the Democratic candidate. 
The State of Florida certified Vern Buchanan the winner of the 
election. The margin of victory was 369 votes out of a total of 238,249 
votes counted. Table 1 summarizes the results of the election and shows 
that the results from Sarasota County exhibited a significantly higher 
undervote rate than in the other counties in the congressional 
district. 

Table 1: Results from 2006 General Election for Florida Congressional 
District 13: 

County: Charlotte; 
Buchanan: 4,460; 
Jennings: 4,277; 
Undervotes: 225; 
Total ballots cast: 8,962; 
Percentage undervote: 2.51. 

County: DeSoto; 
Buchanan: 3,471; 
Jennings: 3,058; 
Undervotes: 142; 
Total ballots cast: 6,672; 
Percentage undervote: 2.13. 

County: Hardee; 
Buchanan: 2,629; 
Jennings: 1,686; 
Undervotes: 269; 
Total ballots cast: 4,584; 
Percentage undervote: 5.87. 

County: Manatee; 
Buchanan: 50,117; 
Jennings: 44,432; 
Undervotes: 2,274; 
Total ballots cast: 96,828; 
Percentage undervote: 2.35. 

County: Sarasota; 
Buchanan: 58,632; 
Jennings: 65,487; 
Undervotes: 18,412; 
Total ballots cast: 142,532; 
Percentage undervote: 12.92. 

County: Total; 
Buchanan: 119,309; 
Jennings: 118,940; 
Undervotes: 21,322; 
Total ballots cast: 259,578; 
Percentage undervote: [Empty]. 

Source: GAO analysis of Florida Division of Elections, Charlotte 
County, DeSoto County, Hardee County, Manatee County, and Sarasota 
County data. 

Note: Numbers do not add up because of overvotes - where voters select 
more than the maximum number of candidates allowed in a race; in this 
case, a ballot that had votes for both Buchanan and Jennings. 

[End of table] 

In Florida, the Division of Elections in the Secretary of State's 
office helps the Secretary carry out his or her responsibilities as the 
chief election officer. The Division of Elections is responsible for 
establishing rules governing the use of voting systems in Florida. 
Voting systems cannot be used in any county in Florida until the 
Florida Division of Elections has issued a certification of the voting 
system's compliance with the Florida Voting System Standards.[Footnote 
2] The Florida Voting Systems Certification program is administered by 
the Bureau of Voting Systems Certification in the Division of 
Elections. 

An elected supervisor of elections is responsible for implementing 
elections in each county in Florida in accordance with Florida election 
laws and rules. The supervisor of elections is responsible for the 
purchase and maintenance of the voting systems as well the preparation 
and use of the voting systems to conduct each election. 

Sarasota County Used ES&S Voting Systems in 2006 General Elections: 

In the 2006 general election, Sarasota County used voting systems 
manufactured by ES&S. The State of Florida has certified different 
versions of ES&S voting systems. The version used in Sarasota County 
was designated ES&S Voting System Release 4.5, Version 2, Revision 2, 
and consisted of iVotronic DREs, a Model 650 central count optical scan 
tabulator for absentee ballots, and the Unity election management 
system. It was certified by the State of Florida on July 17, 2006. The 
certified system includes different configurations and optional 
elements, several of which were not used in Sarasota County. 

The election management part of the voting system is called Unity; the 
version that was used was 2.4.4.2. Figure 1 shows the overall election 
operation using the Unity election management system and the iVotronic 
DRE. 

Figure 1: Overview of Election Operation Using the Unity Election 
Management System and iVotronic DRE: 

[See PDF for image] 

This figure is an illustration of flow of election operations, as 
follows: 

Election Data Manager: Program, store and format election data for a 
jurisdiction; flows to: Ballot Image Manager: Create paper ballot 
layouts and create information for personalized electronic ballot to be 
used in iVotronic DREs; flows to: Hardware Programming Manager: Copy 
election definitions for iVotronic DREs into PEBs; flows to: Precinct 
Count (iVotronic DRE): iVotronic DREs are used to capture votes and 
tabulate votes for a precinct; flows to: Data Access Manager, then to 
Election Reporting Manager, then to election reports. 

Precinct Count (iVotronic DRE) also: Copy precinct-level votes from 
PEBs into Election Reporting Manager and ballot images and event logs 
from compact flash cards. 

Source: GAO. 

[End of figure] 

Sarasota County used iVotronic DREs for early and election day voting. 
Specifically, Sarasota County used the 12-inch iVotronic DRE, hardware 
version 1.1 with firmware version 8.0.1.2.[Footnote 3] Some of the 
iVotronic DREs are configured with Americans with Disabilities Act 
(ADA) functionality, which includes the use of audio ballots. The 
iVotronic DRE uses a touch screen--a pressure-sensitive graphics 
display panel--to display and record votes (see fig. 2). 

Figure 2: The iVotronic DRE Voting System and Its Components. 

[See PDF for image] 

This is a photograph of the iVotronic DRE Voting System, highlighting 
the following components: connection to communications pack and printer 
(removed during voting); Vote button; Personalized electronic ballot; 
and Touch screen. 

Source: GAO. 

[End of figure]  

The machine has a storage case that also serves as the voting booth. 
The operation of the iVotronic DRE requires using a personalized 
electronic ballot (PEB), which is a storage device with an infrared 
window used for transmission of ballot data to and from the iVotronic 
DRE. The iVotronic DRE has four independent flash memory modules, one 
of which contains the program code--firmware--that runs the machine and 
the remaining three flash memory modules store redundant copies of 
ballot definitions, machine configuration information, ballots cast by 
voters, and event logs. The iVotronic DRE includes a VOTE button that 
the voter has to press to cast a ballot and record the information in 
the flash memory. The iVotronic DRE also includes a compact flash card 
that can be used to load sound files onto iVotronic DREs with ADA 
functionality. The iVotronic DRE's firmware can be updated through the 
compact flash card. Additionally, at the end of polling, the ballots 
and audit information are to be copied from the internal flash memory 
module to the compact flash card. 

To use the iVotronic DRE for voting, a poll worker activates the 
iVotronic DRE by inserting a PEB into the PEB slot after the voter has 
signed in at the polling place. After the poll worker makes selections 
so that the appropriate ballot will appear, the PEB is removed and the 
voter is ready to begin using the system. The ballot is presented to 
the voter in a series of display screens, with candidate information on 
the left side of the screen and selection boxes on the right side (see 
fig. 3). 

Figure 3: Second Ballot Page Showing the Congressional and 
Gubernatorial Races in Sarasota County's 2006 General Election: 

[See PDF for image] 

This figure is an illustration of the ballot used in the general 
election. 

Source: Sarasota County Supervisor of Elections. 

[End of figure]  

The voter can make a selection by touching anywhere on the line, and 
the iVotronic DRE responds by highlighting the entire line and 
displaying an X in the box next to the candidate's name. The voter can 
also change his or her selection by touching the line corresponding to 
another candidate or by deselecting his or her choice. "Previous Page" 
and "Next Page" buttons are used to navigate the multipage ballot. 
After completing all selections, the voter is presented with a summary 
screen with all of his or her selections (see fig. 4). From the summary 
screen, the voter can change any selection by selecting the race. The 
race will be displayed to the voter on its own ballot page. When the 
voter is satisfied with the selections and has reached the final 
summary screen, the red VOTE button is illuminated, indicating the 
voter can now cast his or her ballot. When the VOTE button is pressed, 
the voting session is complete and the ballot is recorded on the 
iVotronic DRE. In Sarasota County's 2006 general election, there were 
nine different ballot styles with between 28 and 40 races, which 
required between 15 and 21 electronic ballot pages to display, and 3 to 
4 summary pages for review purposes. 

Figure 4: First Summary Page in Sarasota County's 2006 General 
Election: 

[See PDF for image] 

This figure is an illustration of the summary ballot used in the 
general election. 

Source: Sarasota County Supervisor of Elections. 

[End of figure]  

Analysis of Election Data Shows that Undervote Was Distributed across 
All Machines and Precincts: 

Our analysis of the 2006 general election data from Sarasota County 
does not identify any particular voting machines or machine 
characteristics that could have caused the large undervote in Florida's 
13th Congressional District race. The undervotes in Sarasota County for 
the congressional race were generally distributed across all machines 
and precincts. Using voting system data that we obtained from Sarasota 
County, we found that 1,499 iVotronic DREs recorded votes in the 2006 
general election; 84 iVotronic DREs recorded votes during early voting, 
and 1,415 iVotronic DREs recorded votes on election day.[Footnote 4] 
Using these data, we verified that the vote counts for the contestant, 
contestee, and undervotes match the reported vote totals for Sarasota 
County in Florida's 13th Congressional District race. As can be seen in 
table 2, the undervote rate in early voting was significantly higher 
than in election day voting.[Footnote 5] 

Table 2: Undervotes in Florida's 13th Congressional District Race 
during Early and Election Day Voting: 

Machines: 
All voters: 1,499; 
Early voters: 84; 
Election day voters: 
1,415. 

Ballots cast: 
All voters: 119,919; 
Early voters: 30,877; 
Election day 
voters: 89,042. 

Undervotes: 
All voters: 17,846; 
Early voters: 5,445; 
Election day 
voters: 12,401. 

Undervote rate: 
All voters: 14.88%; 
Early voters: 17.63%; 
Election day 
voters: 13.93%. 

Source: GAO analysis of Sarasota County data. 

[End of table] 

The range of the undervote rate for all machines was between 0 and 49 
percent, with an average undervote rate of 14.3 percent. When just the 
early voting machines are considered, the undervote rate ranged between 
5 and 28 percent. The largest number of undervotes cast on any one 
machine on election day was 39. While the range of ballots cast on any 
one machine on election day was between 1 and 121, the median number of 
ballots cast on any one machine was 66. The range of undervote rate by 
precinct was between 0 and 41 percent, and the average undervote by 
precinct was about 14.8 percent. 

Prior Tests and Reviews Provide Some Assurance, but Do Not Provide 
Reasonable Assurance That the iVotronic DREs Did Not Contribute to the 
Undervote: 

Prior to the elections, Sarasota County's voting systems were subjected 
to several different tests that included testing by the manufacturer, 
certification testing by the Florida Division of Elections, testing by 
independent testing authorities, and logic and accuracy testing by 
Sarasota County's Supervisor of Elections. After the 2006 general 
election, an audit of Sarasota County's election was conducted by the 
State of Florida that included a review of the iVotronic source code, 
parallel tests, and an examination of Sarasota County's election 
procedures. Although these tests and reviews provide some assurance, as 
do certain controls that were in place during the election, that the 
voting systems in Sarasota County functioned correctly, they do not 
provide reasonable assurance that the iVotronic DREs did not contribute 
to the undervote. 

Prior Tests and Reviews of Sarasota County's Voting Systems Provide 
Useful Information, but Have Some Shortcomings: 

According to ES&S officials, ES&S tested the version of the iVotronic 
DRE that was used in Sarasota County in 2001-2002, but they could not 
provide us documentation for those tests because the documentation had 
not been retained. 

The Florida Division of Elections conducted certification testing of 
the iVotronic DRE and the Unity election management system before 
Sarasota County acquired the system from the manufacturer. The 
certification process included tests of the election management system 
and the conduct of mock primary and general elections on the entire 
voting system. ES&S Voting System, Release 4.5, Version 2, Revision 2, 
was certified by the Florida Division of Elections on July 17, 2006. 
According to Florida Division of Elections officials, testing of each 
version focuses on the new components, and components that were 
included in prior versions are not as vigorously tested. The 8.0.1.2 
version of the iVotronic firmware was first tested as a part of ES&S 
Release 4.5, Version 1, which was certified in 2005. Version 2 
introduced version 2.4.4.2 of the Unity Election Management System, 
which was certified in August 2005. Certification testing was conducted 
on software that was received from an independent test authority, who 
witnessed the building of the firmware from the source code. An 
independent test authority also conducted environmental testing of the 
iVotronic DRE in 2001 that was relied upon by the Florida Division of 
Elections for certification. 

A logic and accuracy test was conducted by Sarasota County on October 
20, 2006, on 32 iVotronic DREs, and it successfully verified that all 
ballot positions on all nine ballot styles could be properly recorded. 
In addition, the use of a provisional ballot and audio ballot were 
tested, as well as machines configured for early voting with all nine 
ballot styles. 

After the 2006 general election, the Florida Division of Elections 
conducted an audit of Sarasota County's 2006 general election that 
included two parallel tests, an examination of the certified voting 
system and conduct of election by Sarasota County's elections office, 
and an independent review of the iVotronic DRE firmware's source code. 
After the conduct of this audit, the audit team concluded that there 
was no evidence that suggested the official election results were in 
error or that the voting systems contributed to the undervote in 
Sarasota County.[Footnote 6] The parallel tests were performed using 10 
iVotronic DREs--5 used in the 2006 general election and 5 that were not 
used. Four of the machines in each test replicated the votes cast on 
four election day iVotronic DREs. The fifth machine in each test used 
an ad hoc test script that involved picking a random vote pattern along 
with a specific vote selection pattern picked from 10 predetermined 
vote patterns for the 13th Congressional District for each ballot cast. 
The audit report asserts that testing a total of 10 machines is more 
than adequate to identify any machine problems or irregularities that 
could have contributed to undervotes in the Florida-13 race. However, 
we concluded that the results from the testing of 10 machines cannot be 
applied to all 1,499 iVotronic DREs used during the 2006 general 
election because the sample was not random and the sample size was too 
small. 

In examining whether voting systems that were used in Sarasota County 
matched the systems that were certified by the Florida Division of 
Elections, the Florida audit team examined the Unity election 
management system and the firmware installed on six iVotronic DREs. The 
audit team confirmed that the software running on the Unity election 
management system and the firmware in the six iVotronic DREs matched 
the certified versions held in escrow by the Florida Division of 
Elections. On the basis of its review, the audit team concluded that 
there is no evidence to indicate that the iVotronic DREs had been 
compromised or changed. We agree that the test verifies that those six 
machines were not changed, but any extrapolation beyond this cannot be 
statistically justified because the size of the sample is too small. 
Therefore, these tests cannot be used to obtain reasonable assurance 
that the 1,499 machines used in the general election used the certified 
firmware. 

A software review and security analysis of the iVotronic firmware 
version 8.0.1.2 was conducted by a team led by Florida State 
University's SAIT Laboratory. The eight experts in the software review 
team attempted to confirm or refute many different hypotheses that, if 
true, might explain the undervote in the race for the 13th 
Congressional District. In doing so, they made several observations 
about the code, which we were able to independently verify. The 
software review and our verification of the observations were helpful, 
but a key shortcoming was the lack of assurance whether the source code 
reviewed by the SAIT team or by us, if compiled, would correspond to 
the iVotronic firmware that was used in Sarasota County for the 2006 
election. According to ES&S and Florida Division of Elections 
officials, in May 2005 an independent testing authority witnessed the 
process of compiling the source code and building the version of 
firmware that was eventually certified by the Florida Division of 
Elections. According to ES&S officials, if necessary, ES&S can recreate 
the firmware from the source code, but the firmware would not be 
exactly identical to the firmware certified by the Florida Division of 
Elections because the embedded date and time stamp in the firmware 
would be different. 

The software review team also looked for security vulnerabilities in 
software that could have been exploited to cause the undervote. 
Although the team found several software vulnerabilities, the team 
concluded that none of them were exploited in Sarasota in a way that 
would have contributed to the undervote. We did not independently 
verify the team's conclusion. 

Reasonable Assurance of Some Voting System Objectives Has Been 
Achieved: 

The Unity election management system and the iVotronic DREs are the 
major voting system components that may require testing to determine 
whether they contributed to the large undervote in Sarasota County. Our 
review of tests already conducted and documentation from the election 
provide us reasonable assurance that the key functions of the Unity 
election management system--election definition and vote tabulation-- 
did not contribute to the undervote. The election definitions created 
using the Unity election management system are tested during logic and 
accuracy testing to demonstrate that they include all races, 
candidates, and issues and that each of the items can be selected by a 
voter. The votes tabulated on the iVotronic DRE at each precinct 
matched the data uploaded to the Unity election management system, and 
the totals from the precinct results tapes agree with that obtained by 
Unity. Further, the state audit confirmed that the Unity election 
management system software running in Sarasota County matched the 
escrowed version certified by the Florida Division of Elections. 

We have reasonable assurance that the number of ballots recorded by the 
iVotronic DREs is correct because this number is very close to the 
number of people recorded on the precinct registers as showing up at 
the polling places to vote either during early voting or on election 
day. This assurance also allows us to conclude that issues, such as 
votes cast by "fleeing voters"--votes that are cast by poll workers for 
voters who leave the polling place before pressing the button to cast 
the vote--and the potential loss of votes during a system shutdown, did 
not affect the undervote in this election. If these issues had 
occurred, they would have caused a discrepancy between the number of 
voters who sign in at the polling place to vote and the public counts 
recorded on the iVotronic DREs. 

We have reasonable assurance that provisional ballots were 
appropriately handled by the iVotronic DREs and the Unity election 
management system. We also verified that during the Florida 
certification test process, the Division of Elections relied on 
successful environmental and shock testing conducted by an independent 
test authority. 

Reasonable Assurance That All iVotronic DREs Used in the 2006 General 
Election Used Software Certified by the Florida Division of Elections 
Is Lacking: 

We found that prior testing and activities do not provide reasonable 
assurance that all iVotronic DREs used in Sarasota County on election 
day were using the hardware and firmware certified for use by the 
Florida Division of Elections. Sarasota County has records indicating 
that only certified versions were procured from ES&S, and the firmware 
version is checked in an election on the zero and results tapes. 
However, because there was no independent validation of the system 
versions, we cannot conclude that no modifications were made to the 
systems that would have likely made them inconsistent with the 
certified version. As we previously mentioned, the firmware comparison 
of only 6 iVotronic DREs in the state audit is insufficient to support 
generalization to all 1,499 iVotronic DREs that recorded votes during 
the election. Without reasonable assurance that all iVotronic DREs are 
running the same certified firmware, it is difficult for us to rely on 
the results of other testing that has been conducted, such as the 
parallel tests or the logic and accuracy tests. 

The Ability of Voters to Make Selections in Different Ways and Have 
Their Votes Properly Recorded Has Not Been Fully Tested: 

Prior testing of the iVotronic DREs only verified 13 of the 112 ways 
that we identified that a voter may use to select a candidate in 
Florida's 13th Congressional District race. Specifically, on an 
iVotronic DRE, a voter could (1) initially select either candidate or 
neither candidate (i.e. undervote), (2) change the vote on the initial 
screen, and (3) use a combination of page back and review screen 
options to change or verify his or her selection before casting the 
ballot. By taking into account these variations, our analysis has found 
at least 112 different ways a voter could make his or her selection in 
Florida's 13th Congressional District race, assuming that it was the 
only race on the ballot. Out of 112 different ways to select a 
candidate in the congressional race, Florida certification tests and 
the Sarasota County logic and accuracy tests verified 3 ways to select 
a candidate; and the Florida parallel tests verified 10 ways to select 
a candidate--meaning that of the 112 ways, 13 have been tested. By not 
verifying these different ways to select a candidate, we do not have 
reasonable assurance that the system will properly handle expected 
forms of voter behavior. 

The Effect of Miscalibrated iVotronic DREs Is Unclear: 

During the setup of the iVotronic DRE, sometimes referred to as the 
clear and test process, the touch screens are calibrated by using a 
stylus to touch the screen at 20 different locations. The calibration 
process is designed to align the display screen with the touch screen 
input. It has been reported that a miscalibrated machine could affect 
the selection process by highlighting a candidate that is not aligned 
with what the voter selected. We identified two reported cases on 
election day where the miscalibration of the iVotronic DRE led to its 
closure and discontinued use for the rest of the day. While a 
miscalibrated machine could certainly make an iVotronic DRE harder to 
use, it is not clear it would have helped to contribute to the 
undervote. We did not identify any prior testing or activities that 
would help us understand the effect of a miscalibrated iVotronic DRE on 
the undervote. 

Further Tests Could Provide Increased but Not Absolute Assurance That 
the iVotronic DREs Used in the Election Did Not Cause the Undervote: 

On the basis of our analysis of all prior test and audit activities, we 
propose that a firmware verification test, a ballot test, and a 
calibration test be conducted to try to obtain increased assurance that 
the iVotronic DREs used in Sarasota County during the 2006 general 
election did not cause the undervote. 

We propose that the firmware verification testing be started first, 
once the necessary arrangements have been made, such as access to the 
needed machines and the development of test protocols and detailed test 
procedures. Once we have reasonable assurance that the iVotronic DREs 
are running the same certified firmware, we could conduct the ballot 
test and calibration test on a small number of machines to determine 
whether it is likely the machines accurately recorded and counted the 
ballots. If the firmware verification tests are successfully conducted, 
we would have much more confidence that the iVotronic DREs will behave 
similarly when tested. If there are differences in the firmware running 
on the iVotronic DREs, we would need to reassess the number of machines 
that need to be tested for ballot testing and calibration testing in 
order for us to have confidence that the test results would be true for 
all 1,499 iVotronic DREs used during the election. In other words, if 
we are reasonably confident that the same software is used in all 1,499 
machines, then we are more confident that the results of the other 
tests on a small number of machines can be used to obtain increased 
assurance that the iVotronic DREs did not cause the undervote. Although 
the proposed tests would provide increased assurance, they would not 
conclusively eliminate the machines as a cause of the undervote. 

Conduct Firmware Testing to Verify That the Firmware in the iVotronic 
DREs Used in Sarasota County Matches the Certified Version: 

We propose to conduct a firmware verification test using a statistical 
sampling approach that can provide reasonable assurance that all 1,499 
iVotronic DREs are running the certified version of firmware. The exact 
number of machines that would be tested depends on the confidence level 
desired and how much error can be tolerated. We propose drawing a 
representative sample from all the iVotronic DREs that recorded votes 
in the general election. With a sample size of 115 iVotronic DREs, 
which would be divided between sequestered and nonsequestered machines, 
and assuming that there are no test failures, we would be able to 
conclude with a 99 percent confidence level that no more than 4 percent 
of the 1,499 iVotronic DREs used in the election were using uncertified 
firmware. 

We suggest a test approach similar to what was used by the Florida 
Division of Elections when it verified the firmware for 6 iVotronic 
DREs. We estimate that the firmware testing for 115 machines could be 
conducted in about 5 to 7 days and would require about 5 or 6 people, 
once the necessary arrangements have been made. The machines would be 
transported to a test facility specified by Sarasota County election 
officials where we could perform the test. The activities involved in 
conducting a firmware validation test would include locating and 
retrieving the selected iVotronic DRE from the storage facility, 
transporting it to the test facility, opening the DRE, extracting the 
chip with the firmware, reading the contents of the chip using a 
specialized chip reader, and conducting a comparison between the 
contents and the certified firmware to determine if any differences 
exist. To conduct this test, we would need commercially available 
specialized hardware and software similar to that used by the Florida 
Division of Elections in its firmware comparison test. 

Conduct Ballot Testing of iVotronic DREs to Confirm Correct Operation: 

We propose conducting ballot testing on 10 iVotronic DREs, each 
configured with one of the nine different ballot styles, with the 10th 
machine configured as an early voting machine with all nine ballot 
styles. We would test 112 ways to select a candidate on the early 
voting machine. On the election day machines, we would test the 112 
different ways distributed across the 9 machines in a random manner, 
meaning each machine would on average record 12-13 ballots. Assuming 
that (1) reasonable assurance is obtained that all iVotronic DREs used 
during the election were using the same certified firmware, and (2) we 
found no failures during the ballot testing, this testing would provide 
increased assurance that the iVotronic DREs used during the election, 
both in early voting and in election day voting, were able to 
accurately record and count ballots when using any of the 112 ways to 
select a candidate in the Florida-13 race. 

We would plan to code each ballot by including an identifier in the 
write-in candidate field for either the U.S. senator or governor's 
race. Using this write-in coding, we could examine the ballot image and 
confirm that each ballot was accurately recorded and counted by the 
iVotronic DRE. Any encountered failures would also be more rapidly 
attributed to a specific test case, and we would be able to more 
readily repeat the test case to determine if we have a repeatable 
condition. Testing 112 ways to select a candidate on a single machine 
would also provide us some additional assurance that the volume of 
ballots cast on election day did not cause a problem. We note that 
casting 112 ballots on a single machine is more than that cast on over 
99 percent of the 1,415 machines used on election day. We estimate the 
ballot testing would take about 2 to 3 days and require the equivalent 
of 2 people, once the necessary arrangements have been made. 

Deliberately Miscalibrate an iVotronic DRE to Understand the Effect on 
the Undervote: 

Because little is known about the effect of a miscalibrated machine on 
the behavior of an iVotronic DRE, we propose to deliberately 
miscalibrate an iVotronic DREs and verify the functioning of the 
machine. We propose to identify different ways to miscalibrate a ballot 
and to test ballots on the miscalibrated iVotronic DRE to verify that 
it still properly records votes. With this test we would confirm 
whether (1) the review screen displays the same selection in the 
Florida-13 race as was highlighted in the selection screen, and (2) 
that the vote is recorded as it was displayed on the review screen. 
Again, we would plan to use the write-in candidate option to verify the 
proper recording of the ballot. This test would demonstrate whether the 
system correctly records a vote for the race and hence whether it 
contributed to the undervote. We estimate that the calibration test 
could be completed in about 1 day by 2 people, once the necessary 
arrangements have been made. 

Several Matters Remain to Be Addressed to Conduct Further Testing: 

Should the task force ask us to conduct the proposed testing, we want 
to make the task force aware of several other matters that would need 
to be addressed before we could begin testing. These activities would 
require some time and resources to complete before testing could 
commence. 

First, we would need to gain access to iVotronic DREs that have been 
subject to a sequestration order in the state court system of Florida. 
If we do not have access to the needed machines, we would be unable to 
obtain reasonable assurance that the machines used on election day were 
using certified software, and without this assurance, the results from 
prior tests and any results of our ballot and calibration tests would 
be less meaningful because we would be unable to apply the results to 
all 1,499 iVotronic DREs used during the election. Second, we would 
need to agree upon an appropriate facility for the tests. Sarasota 
County Supervisor of Elections has indicated that we can use its 
warehouse space, but because of upcoming elections in November and 
January, the only time the election officials would be able to provide 
us this space and the necessary support is between November 26 and 
December 7, 2007. If testing cannot be completed during this time 
period, Sarasota County officials stated that they would not be able to 
assist us until February 2008. Third, some tests may require 
commercially available specialized software, hardware, or other tools 
to conduct the tests. We would need to make arrangements to either 
borrow or to purchase such testing tools before commencing testing. 
Fourth, in order to conduct any tests, we would need to develop test 
protocols and detailed test procedures and steps. We also anticipate 
that we would need to conduct a dry run, or dress rehearsal, of our 
test procedures to ensure that our test tools function properly and 
that our time estimates are reasonable. Finally, we would need to make 
arrangements for video recording of our testing. It would be our 
preference to have a visual record of the tests to document the actual 
test conduct and to facilitate certain types of test analysis. 

Other Observations on Touch Screen Voting Systems: 

We recognize that human interaction with the ballot layout could be a 
potential cause of the undervote. Although we have not explored this 
issue in our review, we note that there is an ongoing academic study 
that is exploring this issue using voting machines obtained from ES&S. 
We believe that such experiments could be useful and could provide 
insight into the ballot layout issue. 

During our review, we noted that several suggestions have been offered 
as possible ways to establish that voters are intentionally undervoting 
and to provide some assurance that the voting systems did not cause the 
undervote. First, a voter-verified paper trail could provide an 
independent confirmation that the touch screen voting systems did not 
malfunction in recording and counting the votes from the election. The 
paper trail would reflect the voter's selections and, if necessary, 
could be used in the counting or recounting of votes. This issue is 
recognized in the Florida State University SAIT source code review as 
well as the 2005 and draft 2007 Voluntary Voting Systems Guidelines 
prepared for the Election Assistance Commission. We have previously 
reported on the need to implement such a function properly.[Footnote 7] 
Second, explicit feedback to voters that a race has been undervoted and 
a prompt for voters to affirm their intent to undervote might help 
prevent many voters from unintentionally undervoting a race. On the 
iVotronic DREs, such feedback and prompts are provided only when the 
voter attempts to cast a completely blank ballot, but not when a voter 
undervotes in individual races. Third, offering a "none of the above" 
option in a race would provide voters with the opportunity to indicate 
that they are intentionally undervoting. The State of Nevada provides 
this option in certain races in its elections. Decisions about these or 
other suggestions about ballot layout or voting system functions should 
be informed by human factors studies that assess their effectiveness in 
accurately recording voters' preferences, making voting systems easier 
to use, and preventing unintentional undervotes. 

Conclusions: 

The high undervote encountered in Sarasota County in the 2006 election 
for Florida's 13th Congressional District has raised questions about 
whether the voting systems accurately recorded and counted the votes 
cast by eligible voters. Other possible reasons for the undervote could 
be that voters intentionally undervoted or voters did not properly cast 
their ballots on the voting systems, potentially because of issues 
relating to the interaction between voters and the ballot. The focus of 
our review has been to determine whether the voting systems--the 
iVotronic DREs, in particular--contributed to the undervote. We found 
that the prior reviews of Sarasota County's 2006 general election have 
provided valuable information about the voting systems. Our review 
found that in some cases we were able to rely on this information to 
eliminate areas of concern. This allowed us to identify the areas where 
increased assurances were needed to answer the questions being raised. 
Accordingly, the primary focus of the tests we are proposing is to 
obtain increased assurance that the results of the prior reviews and 
our proposed testing can be applied to all the iVotronic DREs used in 
the election. Our proposed tests involving the firmware comparison, 
ballot testing, and calibration testing could help reduce the 
possibility that the undervote was caused by the iVotronic DREs. 
However, even after completing the tests, we would not have absolute 
assurance that the iVotronic DREs did not play any role in the large 
undervote. Absolute assurance is impossible to achieve because we are 
unable to recreate the conditions of the election in which the 
undervote occurred. By successfully conducting the proposed tests, we 
could reduce the possibility that the iVotronic DREs were the cause of 
the undervote and shift attention to the possibilities that the 
undervote was the result of intentional actions by the voter or voters 
that did not properly cast their votes on the voting system. 

Comments and Our Evaluation: 

We provided draft copies of this statement to the Secretary of State of 
Florida, the Supervisor of Elections of Sarasota County, and ES&S for 
review and comment. The Florida Department of State provided technical 
comments, which we incorporated. The Sarasota County Supervisor of 
Elections appreciated the opportunity to review the draft, but provided 
us no comments. 

In its comments, ES&S stated that it believes that the collective 
results of testing already conducted on the Sarasota County voting 
systems have demonstrated that they performed properly and as they were 
designed to function and that all votes were accurately captured and 
counted as cast in Florida's 13th Congressional District race. Further, 
ES&S asserts that tests and analyses should be conducted to examine the 
effect of the ballot display on the undervote, which it believes is the 
most probable cause of the undervote. 

We disagree that the collective results of testing already conducted on 
the Sarasota County voting systems adequately demonstrate that the 
voting systems could not have contributed to the undervote in the 
Florida-13 race. First, as we have cited, we do not have adequate 
assurance that all the iVotronic DREs used in Sarasota County used the 
firmware certified by the Florida Division of Elections. Without this 
assurance, it is difficult for us to apply the results from the other 
tests to all 1,499 machines that recorded votes during the election 
because we are uncertain that all machines would have behaved in a 
similar manner. Further, we believe that expected forms of voter 
behavior to select a candidate in the Florida-13 race were not 
thoroughly tested. While ES&S asserts that such processes would have no 
effect on the iVotronic DRE's ability to capture and record a voter's 
selection, we did not identify testing that verified this. Further, 
while ES&S states that the testing of a deliberately miscalibrated 
iVotronic DRE would result in a clearly visible indication of which 
candidate was selected, we could not identify any testing that 
demonstrated this. 

We acknowledge that the large undervote in Florida's 13th Congressional 
District race could have been caused by voters who intentionally 
undervoted or voters who did not properly cast their ballots, 
potentially because of issues related to the human interaction with the 
ballot. However, the focus of our review, as agreed with the task 
force, was to review whether the voting systems could have contributed 
to the large undervote. ES&S also provided technical comments, which we 
incorporated as appropriate. 

Mr. Chairman, this completes my prepared statement. I would be happy to 
respond to any questions you or other members of the task force may 
have at this time. 

Contacts and Acknowledgments: 

For further information about this statement, please contact Keith 
Rhodes, Chief Technologist, at (202) 512-6412 or [email protected], or 
Naba Barkakati at (202) 512-4499 or [email protected]. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this statement. Other key contributors to 
this statement include James Ashley, James Fields, Jason Fong, Cynthia 
Grant, Geoffrey Hamilton, Richard Hung, John C. Martin, Jan Montgomery, 
Jennifer Popovic, Sidney Schwartz, and Daniel Wexler. 

[End of section] 

Footnotes:  

[1] Undervotes occur when the number of choices selected by the voter 
is fewer than the maximum allowed for that contest. In this case, it 
means ballots that did not record a selection for either candidate in 
the congressional contest. 

[2] Florida Department of State, Florida Voting System Standards, Form 
DS-DE 101 (Jan. 12, 2005).  

[3] The certified version of ES&S Voting System Release 4.5, Version 2, 
Revision 2, specifies the use of iVotronic hardware version 1.0. 
According to Florida Division of Election officials, hardware version 
1.1 of the iVotronic DRE has been available since at least 2004 and 
should have been included as a part of the certification for ES&S 
Voting System Release 4.5, Version 2, Revision 2. According to ES&S 
officials, iVotronic firmware version 8.0.1.2 runs in exactly the same 
manner on hardware versions 1.0 and 1.1. 

[4] Election day voting is the casting of ballots on election day at 
polling places. Absentee and early voting are programs that permit 
eligible persons to vote prior to election day. Absentee voting is 
conducted by mail in advance of election day and early voting is 
generally in-person voting in advance of election day at specific 
polling locations. 

[5] Early and election day ballots include provisional ballots cast 
during those respective stages of voting and included in the vote 
totals. 160 provisional ballots were included in the vote totals. 37 
provisional ballots were excluded. 

Because the absentee ballots were not cast using iVotronic voting 
systems, we did not verify the absentee ballot counts. When absentee 
ballots are included, a total of 142,532 ballots were cast and a total 
of 18,412 undervotes were recorded. 

[6] Florida Department of State, Audit Report of the Election Systems 
and Software, Inc.'s, iVotronic Voting System in the 2006 General 
Election for Sarasota County, Florida (Tallahassee, Florida: Feb. 
2007), and Security and Assurance in Information Technology Laboratory, 
Florida State University, Software Review and Security Analysis of the 
ES&S iVotronic 8.0.1.2 Voting Machine Firmware (Tallahassee, Florida: 
Feb. 23, 2007). 

[7] GAO, Elections: Federal Efforts to Improve Security and Reliability 
of Electronic Voting Systems Are Under Way, but Key Activities Need to 
Be Completed, GAO-05-956 (Washington, D.C.: Sept. 21, 2005). 

[End of section] 

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