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

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persons running the Venezuelan government to votes in their

favor in order to maintain control of the government.”

(See Exh. 2, pars. 6, 9, 10).

104.

Smartmatic’s incorporators and inventors have backgrounds evidencing

their foreign connections, including Venezuela and Serbia, specifically its

identified inventors:

Applicant: SMARTMATIC, CORP.

Inventors: Lino Iglesias, Roger Pinate, Antonio Mugica, Paul Babic,

Jeffrey Naveda, Dany Farina, Rodrigo Meneses, Salvador Ponticelli,

Gisela Goncalves, Yrem Caruso. 19

105.

The presence of Smartmatic in the United States—owned by foreign

nationals, and Dominion, a Canadian company with its offices such as the

Office of General Counsel in Germany, would have to be approved by CFIUS.

CFIUS was created in 1988 by the Exon-Florio Amendment to the Defense

Production Act of 1950. CFIUS’ authorizing statute was amended by the

Foreign Investment and National Security Act of 2007 (FINSA).

As amended, section 721 of the DPA directs "the President, acting

through [CFIUS]," to review a "covered transaction to determine

the effects of the transaction on the national security of the

United States." 50 U.S.C. app. § 2170(b)(1)(A). Section 721 defines

19 https://patents.justia.com/assignee/smartmatic-corp

45

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