OVSTA
Public Hearing Transcripts
Liberty Vote ImageCast 5.2 Remote Accessible Vote by Mail
Read the report at Liberty Vote Systems ↗
STATE OF CALIFORNIA
SECRETARY OF STATE
OFFICE OF VOTING SYSTEMS TECHNOLOGY ASSESSMENT
In the Matter of: )
)
PUBLIC HEARING: )
)
DOMINION VOTING SYSTEMS )
)
IMAGECAST REMOTE 5.2 REMOTE )
)
ACCESSIBLE VOTE BY MAIL )
)
SYSTEM )
______________________________)
PUBLIC HEARING
Secretary of State Building
1500 11th Street
Sacramento, California
April 27, 2018
9:00 A.M.
Reported by:
Peter Petty
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APPEARANCES
STAFF
Susan Lapsley, Administration
NaKesha Robinson, OVSTA
Rodney Rodriguez, OVTSA
Todd Ross, OVTSA
CONRACTORS/CONSULTANTS
Mike Santos, SLI Compliance
PUBLIC COMMENT
Fred Nisen, Disability Rights California
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APRIL 27, 2018, 9:03 A.M.
2
SACRAMENTO, CALIFORNIA
3
MS. LAPSLEY: All right. Good morning. Well,
4
it’s a couple minutes after nine. We’ll go ahead and get
5
started. I’d first like to introduce Staff, and then we’ll
6
kind of cover the ground rules of this public hearing.
7
Here on stage, we have Todd Ross, who is a member
8
of the Office of Voting Systems Technology Assessment,
9
OVTSA. I’ll let Mike -- we’ll hold off on Mike, because
10
you’re not a member of OVTSA. You don’t count as Staff.
11
NaKesha Robinson, also a member of OVTSA. And down here we
12
have Rodney Rodriguez, also with OVTSA. Rodney will be
13
handling the timing of public comments, as well as speaker
14
cards, and making sure that everything runs smoothly here
15
as far as sound and getting everyone what they need.
16
Just a few ground rules. There’s no food or
17
drink in the auditorium. We will be taking public comment
18
about the following -- about Dominion Voting Systems
19
ImageCast Remote 5.2, Remote Accessible Vote By Mail
20
System. RAVBM is the abbreviation of that.
21
The Staff Reports, consultant’s reports and other
22
tests are available on our website at
23
www.sos.ca.gov/elections/votingsystemsvendors/dominion.
24
For the system being heard, the Staff Report will be given,
25
then the consultant’s report. After that the vendor will
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have an opportunity to respond, and then it will be open
2
for public comment. All those requesting to speak during
3
the public comment period for the system must complete a
4
speaker request card, which is available -- they are
5
available at the entrance. If you didn’t get one and would
6
like one, please raise your hand and let Rodney know and he
7
can run one to you.
8
Speaking time will be limited to three minutes.
9
The timekeeper will advise when 2 minutes 30 seconds has
10
elapsed, and then again when 3 minutes has elapsed. Rodney
11
wanted to use a big hook today, but we wouldn’t let him.
12
So he’ll let you know by holding up a notice card. A
13
speaker may use additional time that has been ceded to them
14
by a maximum of two other people who have signed a speaker
15
card request. If you wish to cede your time to another
16
speaker, please that person’s name in addition to your own
17
name on your speaker’s request card.
18
We have a small house today, so I won’t give my
19
normal comments about people coming a long ways and being
20
respectful. I assume, looking at the faces here, everyone
21
is very respectful, except for may Waldeep up there in the
22
corner, who has his drink in hand.
23
Please note that the court stenographer is taking
24
a transcription of the meeting today. This means that if
25
you speak, your name and your comments will be part of the
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public record. They will be posted on our internet website
2
at some point, so please state your name clearly for the
3
stenographer prior to beginning.
4
The public hearing is also being videotaped,
5
which will also be part of the public record.
6
Written public comments on this item can be
7
submitted to Voting Systems at sos.ca.gov, or by U.S. Mail
8
to the Secretary of State’s Office, Attention: Voting
9
System Comments, at 1500 11th Street, 6th Floor,
10
Sacramento, California 95814. Any written comments
11
submitted to the Secretary of State, whether they be via
12
email or U.S. Postal, will become, also, part of the
13
record.
14
With that, we’ll go ahead and we will turn it
15
over to NaKesha to give the Staff Report.
16
MS. ROBINSON: All right. Good morning,
17
everyone. Dominion Voting Systems submitted an application
18
for the ImageCast Remote 5.2 System on September 5th, 2017.
19
ImageCast Remote 5.2 is a vendor-hosted application solely
20
for the purposes of ballot marking, pursuant to Elections
21
Code sections 303.3 and 19283. ImageCast Remote 5.2 was
22
evaluated against the applicable portions of the California
23
Voting Systems Standards, or CVSS.
24
Upon receipt of a completed application the
25
Secretary of State released a Request for Quote for
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assistance with source code review, telecommunications and
2
security review, as well as usability, accessibility and
3
privacy testing.
4
Through a formal California contracting process
5
the Secretary of State awarded a contract to SLI
6
Compliance, a division of Gaming Laboratories
7
International, LLC, to assist with testing.
8
Dominion Voting Systems Remote 5.2 Remote
9
Accessible Vote By Mail System application is a web-based
10
interface. The voter can optionally use a screen reader to
11
navigate through the -- through the screens. After marking
12
their cast vote record and reviewing their selection, the
13
voter must print their selections. The printed paper-cast
14
record is returned to the local elections official, where
15
it will be remade into a ballot. The printed paper-cast
16
record and the ballot are kept together for auditing
17
purposes.
18
Accessibility and functional testing of the
19
system was conducted by SOS staff. The functional test was
20
conducted at the Secretary of State’s Office in Sacramento,
21
California during the month of November 2017.
22
End-user accessibility testing was conducted in
23
three waves. Wave one user accessibility testing was
24
performed by nine volunteers throughout the State of
25
California from November 30th to December 1st, 2017. Wave
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two took place from December 4th to December 8th, 2017,
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concluding with wave three from December 18th to December
3
22nd, 2017, where we had 29 volunteer testers. The
4
additional testing was conducted by SLI during the month of
5
March 2018.
6
For the functional test, the Secretary of State’s
7
Office provided Dominion with three test ballot data sets
8
of California elections: one, the State of California
9
Primary Election, which was comprised of a fictional
10
jurisdiction; two, a State of California General Election,
11
which was also a fictional jurisdiction; and last, a local
12
jurisdiction fictional ranked choice election.
13
The system was also exercised for under-votes,
14
over-votes and write-ins. The system successfully warned
15
users of under-votes and over-votes, as well with write-in
16
candidates, it does have a 50 character limit.
17
During accessibility, usability and privacy
18
testing, again, we conducted three waves. And, also, SLI
19
conducted accessibility, usability and privacy testing.
20
During the testing with the end-users that were
21
recruited statewide, the testers were asked to complete
22
pre-test and post-test surveys, documenting such
23
information as demographics, the technology that was used
24
for testing, and the testers post-test experience using the
25
system. The survey results of each are included in
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Attachment A of the Staff Report. Please note that
2
personal identifying information has been redacted.
3
During the testing conducted with end-users,
4
there are approximately 15 technical issues that were
5
identified. Each has a response and/or mitigation, which
6
can be found in the Staff Report.
7
SLI conducted an additional accessibility,
8
usability and privacy test, as well. Phase one of SLI’s
9
testing was a review of the ImageCast Remote 5.2
10
documentation of usability and accessibility performed
11
during system development. Phase two included all
12
accessibility and usability testing. And phase three
13
included privacy testing. Additional details regarding
14
SLI’s testing can be found in the Staff Report, as well as
15
during the next presentation, Mike Santos will elaborate a
16
little bit further.
17
During usability testing, SLI identified one
18
requirement that was not met. That is CVSS 3.2.7.C.2.
19
Review of that requirement showed that navigation keys, up
20
and down arrows, tab did have repetitive effect. Dominion
21
will address that by adjusting their use procedures
22
accordingly.
23
During accessibility testing by SLI, additional
24
testing was also conducted against the applicable portions
25
of section 508. And during that testing, it was determined
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that all requirements were satisfactorily met.
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During privacy testing, SLI evaluated ImageCast
3
Remote for compliance with California Elections Code
4
requirements within an RAVBM system, in addition to the
5
applicable portions of the CVSS. During that testing, all
6
requirements were satisfactorily met and/or covered.
7
And next, during the security and
8
telecommunications testing, SLI conducted a documentation
9
review, functional security testing, and telecommunications
10
and data transmission testing. A summary of each of the
11
applicable standards, as well as whether those standards
12
were met, are covered within the Staff Report.
13
During the security and telecommunication’s
14
testing, SLI did identify two potentially high security
15
vulnerabilities, one being potential cross-sites scripting
16
opportunity and select components of the system. Dominion
17
has provided a vendor mitigation, as well as a response,
18
which can be found within the Staff Report. The second
19
issue, potential sequel injection vulnerabilities arise
20
when user-controllable data is incorporated into database
21
sequel queries in an unsafe manner. And again, Dominion
22
did provide a vendor response, as well as mitigation to
23
that vulnerability.
24
And then finally, during the software review
25
testing, the purpose of this testing was to review and
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identify any discrepancies within the software code and
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compliance with the California Voting System Standards.
3
During that testing, SLI discovered one discrepancy. There
4
were 180 source code requirements found to be at issue with
5
the RAVBMS source code base reviewed. As a result, 108
6
discrepancies were written against the code base. Dominion
7
did provide a mitigation in response to that, as well.
8
And one other item I’d like to go back to, during
9
our end-user testing, one of our test volunteers did
10
identify or make some comments that I did not get a chance
11
to address during the Staff Report, so I’d like to address
12
those now. It is regarding the PIN feature within
13
Dominion’s RAVBM system.
14
So the PIN is a feature that can be turned on and
15
off, just like the capture functionality. Depending upon
16
how the jurisdictions and/or the SOS provides guidance on
17
using those -- issuing PINs. The system also provides
18
options to have a PIN issued via telephone and/or a
19
postcard. And also to be very clear, the RAVBM cast vote
20
record will be remade into a ballot. And while we
21
understand Dominion does have the capability to read those
22
cast vote records directly within their voting system, we
23
must have an official ballot. So all the RAVBM cast vote
24
records will be remade.
25
And with that, that concludes my presentation of
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the Staff Report.
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Next up, we’ll have Mike Santo from SLI.
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MR. SANTOS: Good morning. I am Mike Santos from
4
SLI Compliance. As NaKesha just mentioned, we were tasked
5
with doing source code review, security and vulnerability
6
testing, as well as accessibility, usability and privacy
7
testing.
8
In terms of source code review, there were
9
approximately 319,000 lines of source code and comments
10
that were subjected to review. Some of the criteria that
11
we were using for the review process was adherence to
12
applicable standards of the CVSS, adherence to other
13
applicable coding format conventions and standards,
14
including best practices for the coding languages being
15
used, analysis of the program logic and branching
16
structure, as well as evaluating whether the system is
17
designed in a way that allows meaningful analysis.
18
Also, as NaKesha mentioned, during the source
19
code review there were 180 source code discrepancies that
20
were found. They were -- they covered six different
21
requirements.
22
There were some 80 instances that were noted
23
where lines of source code exceeded more than 120
24
characters in length, 71 instances that were noted where
25
numbers were not set to a constant, 23 instances that were
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noted where variable declarations were without comment, 10
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instances were noted where no default case existed, 2
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instances were noted where variable names were not
4
differing by more than one character were being utilized,
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and there was 1 instance noted where inconsistent
6
indentation was implemented. So that was the findings from
7
the functional system source code review.
8
We also performed a vulnerability review on the
9
source code where we were searching for exposures to
10
commonly-exploited vulnerabilities, evaluating the use and
11
correct implementation of cryptography of key management,
12
evaluating the likelihood of security failures being
13
detected in terms of like audit mechanisms and where the
14
data could be subject to tampering, evaluating the risk
15
that a user can escalate their capabilities beyond those
16
authorized, evaluating the design and implementation to
17
ensure that sound generally-accepted engineering practices
18
are being followed and that the code is being written
19
defensively, evaluating for embedded exploitable code that
20
could be triggered to effect the system.
21
We evaluated the code for dynamic memory access
22
features which would permit the replacement of certified
23
executable code or control data or insertion of exploitable
24
code or data. And we also were evaluating the code for use
25
of runtime scripts, instructions or other control data that
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can affect the operation of security-relative functions or
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the integrity of the data itself.
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So upon looking through those 319,000 lines of
4
code for those criteria, no vulnerabilities were found
5
within the system. And as a result, no findings were
6
written against the code base with regards to
7
vulnerability.
8
We were also tasked with a security review. We
9
looked at various aspects of security, including general
10
access control, access control identification, access
11
control authorization, and general access control.
12
Let’s see here, in terms of general access
13
control, we were looking for authentication that included
14
methods for both the voter-facing application, as well as
15
the administrative application. The security -- the
16
general access control security was tested on the
17
architecture pieces, client application, administrative
18
application, which were accessible remotely.
19
In terms of access control identification, the
20
system was determined to use a client server system to
21
authenticate registered users and serve up the correct
22
ballot for a particular voter using pre-defined ballot
23
rules and voters that can be imported by the jurisdiction.
24
Role-based access controls were determined to be in place
25
for administrative login purposes.
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With regards to access control authorization, all
2
administrative access is controlled by username, password
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combinations, and there is a role-based administrative
4
access in place. Also, the ability to assign voters to
5
different electoral groups or electoral districts, it gives
6
the ability to assign ballots to voters in accordance with
7
specific CVSS rules.
8
For access control analysis, we attempted XSX
9
(phonetic) attacks, sequel injection attacks, direct re-
10
listings, and scans attempting to pull directory file lists
11
scanned for default, http login pages. We scanned for
12
robot text files and pulled SSL certification information.
13
We performed a full vulnerability scan, as well.
14
Sorry.
15
For telecommunications and data transmission, the
16
system utilizes electrical transmissions, and the ballot is
17
sent by SSL. No receipt is utilized to verify the
18
transmission. The client generates a blank ballot which
19
does not contain voting selections, so once the ballot is
20
delivered and until the ballot package is saved there are
21
no external communications between the voter and the ballot
22
delivery system. All interactions remain local to the
23
voter’s environment.
24
In terms of security vulnerabilities, we were
25
tasked with determining, A, if there were security
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vulnerabilities, and B, if there were, to try to indicate
2
the level of exploitation that the vulnerability would
3
require access by.
4
And those are broken down into four different
5
categories: a voter, who usually has low knowledge of the
6
voting machine and design and configuration; a poll worker,
7
who usually also has a low knowledge of the voting design
8
and configuration, but has more access to anything, which
9
in the case of an RAVBM system (indiscernible) going to
10
have poll workers; election official insiders who have a
11
wide range of knowledge of the voting design and
12
configuration and may have unrestricted access to the
13
machine for long periods of time; as well as a fourth
14
category of a vendor insider that has great knowledge of
15
the voting machine design and configuration and have
16
unlimited access to the machine before it’s delivered to
17
the purchaser, and thereafter may have unrestricted access
18
with performing warranty and maintenance service, and when
19
providing election administrative services.
20
The ability to tamper with the client site
21
application is always present due to the fact that there
22
are no server site verifications or validations in place
23
after the ballot has been generated. So at that point, you
24
know, somebody can sit there for days on end and do
25
whatever they want to that ballot. In this context,
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however, the ability to effect large numbers of ballots is
2
reliant upon server site compromise, which may also include
3
distributed denial (phonetic) of service attacks.
4
The voter is given the ability to proof and
5
confirm ballot selections within the system, as well as the
6
printed paper ballot, so there is a final confirmation
7
screen with the system. And then once you’ve printed your
8
paper ballot, you have that ability to do a final check of
9
that ballot prior to submitting it or being cast.
10
Security testing of the server site hosting
11
security included application scanning and vulnerability
12
scanning. The results of the scanning revealed potential
13
vulnerabilities that is estimated would have a minimal
14
impact on the overall security of the application being
15
tested. And those were basically what NaKesha mentioned a
16
few minutes ago and, I guess, is in the final reports on
17
the website.
18
The third area that we were tasked with reviewing
19
was the usability and accessibility testing, as well as
20
privacy testing.
21
In terms of usability and accessibility testing,
22
some of the items that we were looking at were that the
23
system allows the voter, at the voter’s choice -- it’s kind
24
the basics of voting the ballot, that the system would
25
allow the voter, at the voter’s choice, to submit an under-
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voted ballot without correction. That would provide the
2
voter the opportunity to correct the ballot for an under-
3
vote before the ballot is cast and counted.
4
It would prevent voters from selecting more than
5
the allowable number of choices for each contest, so it
6
doesn’t allow over-voting.
7
It provides feedback to the voter before final
8
casting of the ballot that identifies specific contests for
9
which the voter has selected fewer than the allowable
10
number of choices, providing the voter the opportunity to
11
correct the ballot.
12
It allows the voter to change a vote within a
13
contest before advancing to the next contest, to provide
14
navigation controls that allow the voter to advance to the
15
next contest or go back to the previous contest before
16
completing the vote on the contests currently being
17
presented. So it’s really just checking, you know, a lot
18
of the -- some of the basic rules, the no over-voting,
19
letting you know if you’ve under-voted, and allowing you to
20
vote, basically, any contest in any manner in any order
21
that that voter prefers. A voter was able to vote
22
appropriate contests in any manner or order they wished and
23
was notified when under-voting, and was prevented from
24
over-voting.
25
We were also looking at cognitive issues,
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completeness of instructions, availability of assistance
2
from the system, plain language being used, context before
3
actions, no bias among choices, ballot design, conventional
4
use of colors, icons and languages, as well as perceptual
5
issues, including accommodation for color blindness and no
6
reliance solely on color so that color coding is not used
7
as the sole means of conveying information.
8
Interaction issues, we were looking at no page
9
scrolling being allowed, unambiguous feedback for voter’s
10
selection, so that was very obvious that what they were
11
selecting as their choice. We looked for accidental
12
activation, size and separation of touch areas, repeating
13
keys, timing issues, initial system response times, maximum
14
completed response time for vote confirmation, maximum
15
completed system response time for all operations, and
16
voter inactivity time.
17
As NaKesha mentioned, we did see an issue with
18
the no repeating keys, that key presses were allowed to be
19
repeated. And it sounds like Dominion Voting Systems has
20
implemented a mitigation for that.
21
In terms -- we were also looking at alternative
22
languages, general support for alternative languages,
23
complete information in an alternative language,
24
auditability of records for English readers, and voter
25
control of language. An issue that was seen in terms of
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voter control with the language that the system allows the
2
voter to select among the available languages throughout
3
the voting session, while preserving the current votes.
4
So once a voter selects a language and they
5
download that ballot, the connection to the server is
6
broken and that ballot is local only to that device that
7
the voter is voting on. So should they decide to change
8
languages, they would need to go back and access a whole
9
new ballot and it would not carry over anything that they
10
had voted in the first language to a second language, so
11
that was one thing that was noted.
12
There were a number of requirements that were
13
related to hardware in the voting environment where the
14
voter would be casting their ballot that were deemed not
15
applicable as the voter will be utilizing their own
16
equipment, so we really couldn’t speak to hardware-oriented
17
items.
18
In terms or privacy, some of the categories were
19
visual privacy, auditory privacy, and no receipts. And
20
again, this was as a Remote Access Vote-By-Mail System.
21
The voting will occur in an environment of the voter’s
22
choosing. And all privacy issues will be reliant upon
23
where they choose to cast their -- or to mark their
24
ballots.
25
Some final requirements that were looked at were
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related to, I think this is Rule 19295, RAVBM system
2
Requirements, that the system shall not have the
3
capability, including an optional capability, to use a
4
remote server to mark a voter’s selections, transmit it to
5
the server from the voter’s computer via the internet,
6
store any voter identifiable selections on any remote
7
server, or tabulate votes. And it was verified that, as I
8
mentioned a little bit earlier, that once the ballot is
9
delivered to the voter’s personal environment, all
10
connections are removed and there are no remote servers to
11
do any of those things.
12
And that basically concludes --
13
MS. LAPSLEY: Okay.
14
MR. SANTOS: -- SLI’s report.
15
MS. LAPSLEY: Great. Thank you, Mike.
16
So with that, is anyone -- is there anyone from
17
Dominion that would like to respond to either the Staff
18
Report or the consultant’s report?
19
UNIDENTIFIED MALE: No, thank you.
20
MS. LAPSLEY: No, thank you? All right.
21
With that, we’ll go ahead and move to public
22
comments. And right now we have one public speaker card
23
and that’s from Mr. Fred Nisen with Disability Rights of
24
California.
25
Mr. Nisen?
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UNIDENTIFIED MALE: Thank you. We’re from
2
Disability Rights California, and I’m going to be reading
3
his testimony.
4
(On behalf of Fred Nisen.)
5
“Hi. My name is Fred Nisen. I am the Supervising
6
Attorney of the Voting Rights Practice Group at
7
Disability Rights California, California’s protection
8
and advocacy system for people with disabilities.
9
“I, along with other members of my staff, participated
10
in the testing of Dominion’s ImageCast Remote 5.2.
11
After reading through the reports online, these are my
12
following comments.
13
“This PIN process is too cumbersome. It would require
14
the voter have to have some dedication to not give up
15
during this process. I understand that people are
16
concerned with security at this time. However, just
17
giving people more hoops to jump through will not make
18
the system more secure and will scare away people who
19
could benefit from having vote-by-mail be made
20
accessible to them without having to waive their right
21
to a private and independent vote. I have a reason to
22
believe that Dominion is willing to work with counties
23
to make their process less burdensome for voters with
24
disabilities.
25
“As a condition of approval, the Secretary of State’s
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1
Office should require that the voter verification be a
2
one-step process, asking for voter I’D, name and date
3
of birth, similar to other RAVBM systems.
4
“Personally, I found the system easy to use, once I
5
was able to get to the ballot. However, one of our
6
staff members who uses the Java screen reading
7
software on his computer also tested the system,
8
including the problems with the audio instructions on
9
how to complete a write-in candidate selection. He
10
also found a problem with the audio instructions on
11
how to return to the previous screen.
12
“I also noted in the Staff Report that the Secretary
13
of State’s Office expects counties to remake all the
14
ballots that come in using this Remote Accessible
15
Vote-By-Mail System. It is my understanding that when
16
counties are using an ImageCast Voting System, as well
17
as ImageCast Remote 5.2, they can simply be slipped
18
into the ballot box when it is removed from the
19
envelope. This would make the voter’s choices as
20
private as any other vote-by-mail voters since they do
21
not have to use copy to a paper ballot.
22
“In fact, I understand that a county that uses
23
Dominion ICX Ballot Marking Device as their
24
accessibility voting system can use the ICX to
25
duplicate the remote ballot. I am not advocating that
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a county purchase a particular system, but if a county
2
uses ImageCast to count their ballots and they use
3
this Accessible Vote-By-Mail System, they should be
4
able to input the Accessible Vote-By-Mail ballots
5
directly into the ballot counter. This would ensure
6
that the voter has a private and independent ballot to
7
the ballot box without anybody filling out a ballot
8
for them.
9
“Thank you.”
10
MS. LAPSLEY: Great. Thank you.
11
Thank you, Mr. Nisen.
12
Seeing no other members of the public wishing to
13
have -- to make public comment, we will be accepting public
14
comment through May 6th, again, as I indicated before, to
15
the Voting Systems at sos.ca.gov email address. People can
16
feel free to send them electronically, or via U.S. Mail to
17
Secretary of State, Attention: Voting System Comment, 1500
18
11th Street, 6th Floor, Sacramento, California 95814.
19
And that with, we’ll go ahead and conclude this
20
public hearing. Again, I thank everyone for coming and for
21
your time today. Thank you.
22
(The hearing concluded at 9:39 a.m.)
23
24
25
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REPORTER’S CERTIFICATE
I do hereby certify that the testimony in
the foregoing hearing was taken at the time and
place therein stated; that the testimony of
said witnesses were reported by me, a certified
electronic court reporter and a disinterested
person, and was under my supervision thereafter
transcribed into typewriting.
And I further certify that I am not of
counsel or attorney for either or any of the
parties to said hearing nor in any way interested
in the outcome of the cause named in said
caption.
IN WITNESS WHEREOF, I have hereunto set my
hand this 10th day of May, 2018.
PETER PETTY
CER**D-493
Notary Public
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CERTIFICATE OF TRANSCRIBER
I do hereby certify that the testimony
in the foregoing hearing was taken at the
time and place therein stated; that the
testimony of said witnesses were transcribed
by me, a certified transcriber and a
disinterested person, and was under my
supervision thereafter transcribed into
typewriting.
And I further certify that I am not
of counsel or attorney for either or any of
the parties to said hearing nor in any way
interested in the outcome of the cause named
in said caption.
I certify that the foregoing is a
correct transcript, to the best of my
ability, from the electronic sound recording
of the proceedings in the above-entitled
matter.
May 10, 2018
MARTHA L. NELSON, CERT**367
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