United States

Konnech Developed UOCAVA Systems to Transmit Votes (China)

Disputed Fact Konnech Inc., an East Lansing, Michigan-based election software company, provided poll worker management, election logistics, and scheduling software to election offices across the United States – including multiple Michigan jurisdictions. Forensic investigation revealed that Konnech transferred sensitive U.S. election data – including poll worker personally identifiable information (PII), building schematics, and operational logistics

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Hart InterCivic Employees Former Smartmatic Employee from Venezuela as Senior VP (Venezuela)

Established Fact Heider Garcia, currently Vice President of Customer Success at Hart InterCivic — one of the three vendors whose equipment is used to count ballots for the majority of American voters — spent over a decade at Smartmatic (2003–2016), where he held progressively senior roles including Native Solutions Deployment Coordinator, Solution Manager, and lead

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ESS CEO Testified Under Oath – DS200 Programmable Logic Devices Manufactured in China (China)

Established Fact During a January 9, 2020 Congressional hearing before the House Administration Committee – held less than ten months before Election Day – ESS CEO Tom Burt testified under oath that the programmable logic devices (PLDs) used within ESS tabulators, specifically the DS200 widely deployed in Wisconsin, are manufactured in a factory in China.

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Dominion Manufactures Election System Components in China (China)

Established Fact Internal Dominion Voting Systems communications (Chaudhry to Poulos, April 14, 2020) confirm that 39–48% of programmable components in the ImageCast Precinct (ICP) and ImageCast Evolution (ICE) tabulators were sourced from China. These are the machines that scanned and tabulated ballots in the November 2020 election. These machines were deployed at scale in decisive

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Smartmatic DNA Found Throughout Leading U.S. Electronic Voting Systems (Venezuela)

Disputed Fact Modern Dominion, Hart InterCivic and ES&S systems have a common lineage that retains Smartmatic code and vulnerabilities. These vulnerabilities, which include plaintext password storage, unencrypted source code, allowing multiple active project files, and remote access design features, were originally designed—not accidental—for potential election manipulation. Smartmatic’s financial motives and political partnerships incentivized maintaining exploitable control features.

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ElectionSource Battery-Removal Directive – Vendor-Directed Destruction of Configuration Data (MI)

Established Fact Dominion subcontractor ElectionSource directed county clerks, including Oceana County, to allow ElectionSource staff to conduct “preventative maintenance” including removal of internal batteries – which resets machines to factory defaults, erasing server connection settings, configuration data, and logs critical to forensic analysis. Battery removal was not listed as a scheduled maintenance item in the

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Physical Obstruction of Poll Challengers at TCF Center, Detroit (MI)

Established Fact At approximately 1:00 p.m. on November 4, Detroit Department of Elections officials closed the TCF Center AVCB doors to credentialed GOP challengers citing overcrowding – while simultaneously admitting uncredentialed Democrat-aligned operatives. Windows were subsequently covered with cardboard pizza boxes to prevent excluded challengers from observing counting through glass, specifically timed to coincide with

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State-Directed Destruction of Electronic Pollbook Data (MI)

Established Fact The Michigan Bureau of Elections, under Secretary of State Jocelyn Benson, issued a February 12, 2021, directive to local clerks explicitly ordering deletion of electronic pollbook software and associated files – directly contradicting 52 U.S.C. 20702’s unconditional 22-month federal retention mandate. The Michigan Senate Oversight Committee characterized the directive as standard practice; no

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Destruction of Ballot Images Statewide – Systematic Non-Preservation (GA)

Established Fact Fulton County admitted in federal court (Curling v. Raffensperger) to destroying the majority of in-person ballot images from the November 3 original count. A statewide VoterGA survey found that 74 of 159 Georgia counties failed to produce ballot images; 56 provided written admissions of non-preservation. The Secretary of State’s post-election Official Elections Bulletin

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False Attestations of Machine Audits That Never Occurred (GA)

Established Fact The Secretary of State publicly represented that forensic audits of voting machines had been conducted in multiple counties. Five of six counties named by the Secretary of State as having been audited confirmed in writing that no such audit had taken place. The sixth county did not respond. Citations Brief of Amici Curiae

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