COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

foreign interference and insider tampering. That’s true even if simple human
error or local maneuvering for political advantage are more likely threats 15 .
100.
A Penn Wharton Study from 2016 concluded that “Voters and their
representatives in government, often prompted by news of high-profile voting
problems, also have raised concerns about the reliability and integrity of the
voting process, and have increasingly called for the use of modern technology
such as laptops and tablets to improve convenience.” 16
101.
As evidence of the defects or features of the Dominion Democracy Suite,
as described above, the same Dominion Democracy Suite was denied
certification in Texas by the Secretary of State on January 24, 2020
specifically because of a lack of evidence of efficiency and accuracy and
to be safe from fraud or unauthorized manipulation. 17
15
See Threats to Georgia Elections Loom Despite New Paper Ballot Voting, By Mark Niesse, The
Atlanta Journal-Constitution and (The AP, Vote-by-Mail worries: A leaky pipeline in many states,
August 8, 2020).
16
Penn Wharton Study by Matt Caufield, The Business of Voting, July 2018.
17
Attached hereto, Exh. 23, copy of Report of Review of Dominion Voting Systems Democracy
Suite 5.5-A Elections Division by the Secretary of State’s office, Elections Division, January 24,
2020.
43