Brief of amicus curiae Whistleblower Aid in opposition to the application for a stay, No. 26A305

… that systems operating exactly as intended, with no software failure of any kind, will reject entire batches of ballots if they find even a single mismatch. And batches can be enormous. The Disclosure describes batches of tens of thousands of ballots, Disclosure ¶ 3(c), and mailings can be far larger than that: Maricopa County, Arizona, “often sends out more than 2 million ballots at a time in its initial mailing.” 7 First, the verification standard is zero percent failure: a batch is deemed non- compliant if a single envelope fails the barcode verification. Disclosure ¶¶ 3, 26–27. Second, the unit of rejection is the batch, not the ballot. When one sampled barcode fails to scan, or scans but is not found in the uploaded Portal data, the Postal Service will reject the entire mailing. Id. ¶ 27. The State is expected to take the whole batch back, locate and cure the single ballot, upload a new batch manifest, and restart the …