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Re: COTS scope

Stan, Vince, et al -

The question that I intended to ask during the teleconference of Nov.
30... Under this proposed scope, how will warranty work on the equipment
be addressed?  If each time a defective driver or other COTS component
is identified and a warranty recall is issued (example: recent recall by
Dell for a defective driver for their RAID configuration used on central
tabulation machines), how will this impact requalification of a system? 
The owners of the systems (jurisdictions) will want to take advantage of
warranty work while still covered by the warranty.   If the warranty
work requires the entire system to be requalified...that could be
impractical, given the time and expense involved, as well as the
potential quantity of warranty claims over the life of the unit.

- Merle

Merle S. King
Chair, CSIS Department
Kennesaw State University
1000 Chastain Road, MB #1101
Kennesaw, GA  30144-5591
voice: 770-423-6354; fax: 770-423-6731

>>> "Stanley A. Klein" <sklein@CPCUG.ORG> 11/22/2004 10:37:40 AM >>>
When P1583 was last balloted, there were numerous comments to the
that COTS should not be exempt from inspection.  An STG was set up to
resolve those and other comments regarding COTS.

The resolution generally was that COTS should undergo the exact same
testing as any other parts of a voting system, unless it had been
previously tested and certified as satisfying the requirements of the

It seems to me that the proper procedure is to incorporate the
resolutions into the P1583 draft and move forward with the document.

We are working to replace an FEC standard that is widely agreed to be
inadequate.  The recent election resulted in numerous reports of
problems with voting systems that can easily be attributed to the
inadequacy of both the FEC standards and the ITA certification

The COTS exemption is a major, glaring loophole in the FEC standard.
Given the technical alternatives for vendors and the procedures used
other mission critical systems, there is absolutely no reason for
allowing the COTS exemption to remain.  Of course it will be initially
inconvenient for vendors, but any meaningful upgrade of the FEC
will involve some initial inconvenience for vendors.

>From my perspective, I see the leadership of P1583 slipping back into
the kinds of process games that just a month or two ago they agreed to
stop playing.  Their credibility is now on the line, and by
the credibility of IEEE Standards as it relates to an issue with major
national attention.

Stan Klein

On Mon, 2004-11-22 at 08:31, R. Mercuri wrote:
> Herb --
> I would like to add my voice to Vince's with regard to the
> attempted replacement of our sub-group's work by material submitted
> by Sandy, who isn't even a member of P1583. We were offended
> at the meeting when it was suggested that Sandy replace us
> as the co-chairs of the working group, and that materials be
> fed to him, rather than us.  We had asked NUMEROUS TIMES for
> input, so if that is going to be provided, it should be to
> Vince and myself, not Sandy. Sandy is welcome to make suggestions,
> of course, but not as a co-chair of the COTS-STG. We had also
> provided material from our sub-committee for the draft document
> that was not included, despite REPEATED requests to do so, and
> this situation continues to be remiss.
> Now it seems that the entire standard will be compromised through
> COTS exemptions.  Sandy's comment "code review of COTS software
> cannot ensure that the COTS firmware/software is failsafe"
> could be equally applied to the entire voting product --
> why bother to have code review at all???  BECAUSE white box
> AND black box testing are NECESSARY to reveal different
> sorts of problems, such as VULNERABILITIES.  Additionally,
> the code MUST be available in order to provide assurances
> and evidence if later problems arise. There are certainly
> ways in which vendors can contract with suppliers to provide
> their code -- the choices they make can/should include products
> that already are open to review (such as Linux or BSD-based).
> The bottom line is that there's no point in having a voting
> system standard if parts of the ballot casting and tabulation
> system are going to be exempt. It is bad enough that the standard
> does not require any auditability feature to provide independent
> recounts -- but to further allow non-inspected components, just
> makes the whole thing a joke.
> I seriously hope that this issue can be resolved appropriately,
> Rebecca Mercuri.
Stanley A. Klein <sklein@cpcug.org>