June 16, 2024

Court permits release of unredacted report on AVC Advantage

In the summer of 2008 I led a team of computer scientists in examining the hardware and software of the Sequoia AVC Advantage voting machine. I did this as a pro-bono expert witness for the Plaintiffs in the New Jersey voting-machine lawsuit. We were subject to a Protective Order that, in essence, permitted publication of our findings but prohibited us from revealing any of Sequoia’s trade secrets.

At the end of August 2008, I delivered my expert report to the court, and prepared it for public release as a technical report with the rest of my team as coauthors. Before we could release that report, Sequoia intervened with the Court, claiming that we were revealing trade secrets. We had been very careful not to reveal trade secrets, so we disputed Sequoia’s claim. In October 2008 the Court ruled mostly in our favor on this issue, permitting us to release the report with some redactions,and reserving a decision on those redacted sections until later.

The hearing on those sections has finally arrived, completely vindicating our claim that the original report was within the parameters of the Protective Order. On October 5, 2010 Judge Linda Feinberg signed an order permitting me to release the original, unredacted expert report, which is now available here.

If you’re curious, you can look at paragraphs 19.8, 19.9, 21.3, and 21.5, as well as Appendices B through G, all of which were blacked out in our previously released report.


  1. Professor, is the ‘detailed legal analysis’ available (due the 5th)… and the response (due today)?

  2. Judge Feinberg’s Order of October 5, 2010 is here.

    Paragraph number 10 is the relevant one. The other paragraphs deal with aspects of the State’s compliance (or lack of compliance) with her previous order.

  3. Please link to Feinberg’s order… wording is of interest.