Established Fact
Election records obtained in response to FOIA request for 2020 election records that were subpoenaed by the MI legislature revealed that LAN-enabled JF-prefix Serial Numbers were deployed in Livonia, MI rather than the “air-gapped” JS-prefix models. The deployed version significantly increased the risk of network-based subversion of the election and indicates that the election was not conducted with an approved scanner configuration thereby serving as grounds for decertification of the results.
Citations
Office of the Special Counsel Second Interim Investigative Report: https://justthenews.com/sites/default/files/2022-03/GablemanReport.pdf | Just The News
Analysis of Livonia 2020 Election subpoena records by Narelle Brigden, https://drive.google.com/file/d/1zXxvq3ErDeJ4I9MO73mHgI_8mvMsbe03/view?usp=drive_link
Michigan Legislature, Joint Legislative Subpoena, December 15, 2020 (“Document 003”), covering 38 document categories, compliance deadline January 12, 2021. Citizens filed FOIA request May 7, 2021 encompassing all 38 subpoena categories. See Kate Riley, Livonia Election Integrity FOIA Timeline (April–June 2021). FOIA production repository: https://drive.google.com/drive/u/0/folders/1IWmi6UvHHWjkOhTb80QJF0s9qr4lKZ7phttps://drive.google.com/drive/u/0/folders/1IWmi6UvHHWjkOhTb80QJF0s9qr4lKZ7p
Canon Inc., DR-G2140/G2110/G2090 User ManualDR-G2140/G2110/G2090 User Manual, p. 5 (distinguishing JF “network models” supporting wired LAN scanning via RJ-45 from JS “USB models” supporting USB connection only). Available at https://gdlp01.c-wss.com/gds/8/0300031738/03/DR-G2140_G2110_G2090_User_Manual_EN.pdfhttps://gdlp01.c-wss.com/gds/8/0300031738/03/DR-G2140_G2110_G2090_User_Manual_EN.pdf.
Canon Inc., imageFORMULA DR-G2140/G2110 Service ManualimageFORMULA DR-G2140/G2110 Service Manual (“The network scanning with wired LAN is supported by the DR-G2140/G2110 network models.”). Available at https://iteminc.info/dlcuploads/Canon-imageFORMULA-DR-G2140–DR-G2110-Service-Manual-66a2c46c692c8.pdfhttps://iteminc.info/dlcuploads/Canon-imageFORMULA-DR-G2140–DR-G2110-Service-Manual-66a2c46c692c8.pdf
U.S. Election Assistance Commission, D-Suite 5.5 Certificate and Scope of CertificationD-Suite 5.5 Certificate and Scope of Certification (FINAL), specifying: “Wide Area Network – Use of Wireless: NO; Local Area Network – Use of Wireless: NO; Local Area Network – Use of TCP/IP: YES (Client/server only); Internet Connectivity: NO.” The Verified Voting Foundation’s profile of the ImageCast Central further confirms that “ImageCast Central workstation is connected to the EMS Local Area Network” — the approved data path routes scanner → workstation via USB, and workstation → EMS via LAN. EAC Scope: https://www.eac.gov/sites/default/files/voting_system/files/DSuite55_CertConf_Scope(FINAL).pdfhttps://www.eac.gov/sites/default/files/voting_system/files/DSuite55_CertConf_Scope(FINAL).pdf. Verified Voting: https://verifiedvoting.org/election-system/dominion-imagecast-central/https://verifiedvoting.org/election-system/dominion-imagecast-central/
The compliance argument proceeds as follows: (a) ECO 100601 approves the DR-G2140 for use in D-Suite 5.5; (b) the D-Suite 5.5 Scope of Certification restricts LAN use to client/server communication between the ICC workstation and EMS server; (c) Canon’s User Manual and Service Manual establish that the JF variant possesses an independent RJ-45 LAN port and LAN-scanning capability; (d) that independent LAN capability has no approved role in the certified data path. Neither the EAC documents nor the Canon documents individually adjudicate the JF/JS compliance question; the argument rests on the combination of both.