"Facing the prospect that President Trump could lose his re-election bid, his cabinet is scrambling to enact regulatory changes affecting millions of Americans in a blitz so rushed it may leave some changes vulnerable to court challenges," reports the New York Times: The effort is evident in a broad range of federal agencies and encompasses proposals like easing limits on how many hours some truckers can spend behind the wheel, giving the government more freedom to collect biometric data and setting federal standards for when workers can be classified as independent contractors rather than employees. In the bid to lock in new rules before Jan. 20, Mr. Trump's team is limiting or sidestepping requirements for public comment on some of the changes and swatting aside critics who say the administration has failed to carry out sufficiently rigorous analysis. Some cases, like a new rule to allow railroads to move highly flammable liquefied natural gas on freight trains, have led to warnings of public safety threats...

If Democrats take control of Congress, they will have the power to reconsider some of these last-minute regulations, through a law last used at the start of Mr. Trump's tenure by Republicans to repeal certain rules enacted at the end of the Obama administration. But the Trump administration is also working to fill key vacancies on scientific advisory boards with members who will hold their seats far into the next presidential term, committees that play an important role in shaping federal rule making...

The Homeland Security Department is also moving, again with an unusually short 30-day comment period, to adopt a rule that will allow it to collect much more extensive biometric data from individuals applying for citizenship, including voice, iris and facial recognition scans, instead of just the traditional fingerprint scan. The measure, which the agency said was needed to curb fraud, would also allow it for the first time to collect DNA or DNA test results to verify a relationship between an application for citizenship and someone already in the United States.

An anonymous reader quotes a report from The Verge: On Thursday, Federal Communications Commission Chairman Ajit Pai said that the agency will seek to regulate social media platforms like Facebook and Twitter at the behest of the Trump administration's executive order signed earlier this year. "Members of all three branches of the federal government have expressed serious concerns about the prevailing interpretation of the immunity set for in Section 230 of the Communications Act. There is bipartisan support in Congress to reform the law," Pai said in a statement Thursday. "Social media companies have a First Amendment right to free speech. But they do not have a First Amendment right to a special immunity denied to other media outlets, such as newspapers and broadcasters."

On Thursday, Pai said that the commission's general counsel said that "the FCC has the legal authority to reinterpret Section 230." He continued, "Consistent with this advice, I intend to move forward with a rulemaking to clarify its meaning." "Pai's decision to move forward with rulemaking follows a series of moderation decisions on Wednesday made by Facebook and Twitter against a New York Post article regarding former Vice President Joe Biden's son, Hunter Biden, who has been the subject of political attacks from the right throughout the 2020 presidential election," the report adds.

Facebook reduced the reach of the story, while Twitter banned linking to the story entirely. "These moves from Facebook and Twitter incited an outcry over conservative bias from Republicans," reports The Verge.

An anonymous reader quotes a report from The Drive: Whether or not you live in Massachusetts, you should be paying attention to a very important vote coming up in November's election. Not for president, or senator, or even city council -- no, Question 1 is a proposition that could dramatically strengthen or weaken the state's landmark right-to-repair law that previously forced automakers to make it easier for you to get your car fixed. Essentially, Massachusetts voters are deciding on whether or not to add "mechanical" vehicle telematics data -- realtime updates from a car's sundry sensors transmitted to an automaker's private servers -- to the list of things OEMs have to share with independent mechanics. Telematics data was purposefully excluded from the original 2013 law, but as cars have gotten more computerized over the last decade, that gap in coverage has grown more pronounced.

The full information about what is appearing on the ballot can be found here. Voting "Yes" to Question 1 would expand access to wirelessly transmitted mechanical data regarding vehicle maintenance and repair. But what makes this a big deal for those outside Massachusetts is that the amendment will require automakers who want to do business in the state to make that data accessible through a smartphone app for owners starting in 2022. Remember, it was the 2013 law's passage that forced automakers to adopt a nationwide right-to-repair standard. Could the same happen with open-access telematics data, which will only grow in importance as more cars add on driver-assist features? Pro-Question 1 organization Massachusetts Right to Repair argues the amendment would futureproof the law for consumers and independent repair shops beyond the state's borders. "Voting 'No' would make no change to governing access over wirelessly transmitted vehicle data, meaning automakers would be under no obligation to provide a standard that consumers could use to analyze diagnostic information other than what is currently provided through the vehicle's OBDII port," adds The Drive.

"[T]he Coalition for Safe and Secure Data has shelled out at least $25.8 million to oppose Question 1, reportedly receiving large seven-figure donations from General Motors, Toyota, Ford, Honda and Nissan. Go figure."

Virginia's voter-registration website went offline Tuesday on the state's last day to register before the Nov. 3 election, in what officials attributed to an accidental cutting of a fiber-optic cable. From a report: The Virginia Information Technologies Agency said that the Verizon cable was inadvertently struck during work for a roadside utilities project and that several agencies were affected. The Virginia Department of Elections didn't immediately respond to a request asking if the deadline to register, originally set for the end of Tuesday, would be extended once service was restored. Voters can also register using a paper application. In recent weeks, voter-registration websites in Florida and Pennsylvania, both considered potentially decisive swing states for the presidential election, crashed due, officials said, to glitches. Florida extended the deadline to register to vote after its registration website malfunctioned. The state's secretary of state cited unprecedented traffic to the site as the cause.

California's elections include grass roots propositions that change the law directly while bypassing legislators. Uber, Lyft, and Uber-owned Postmates (as well as DoorDash and Instacart) have spent $185 million — the most ever spent — pushing a proposition that would keep ride-hail and delivery drivers as independent contractors, reports SFGate. "If it passes...gig corporations won't have to contribute to Social Security, Medicare or unemployment insurance. They won't have to offer paid sick leave, workers compensation or unemployment benefits to drivers."

But the site also investigated what happened shortly after the Uber/Lyft PAC reported an $128,000 expenditure on mailers: Political mailers masquerading as progressive voter guides and endorsing Proposition 22, the initiative backed by Uber and Lyft, are showing up in Southern California voters' mailboxes. The fine print on one mailer says it was prepared by the "Feel the Bern, Progressive Voter Guide," which is not an actual organization. Neither are the "Council of Concerned Women Voters Guide" nor the "Our Voice, Latino Voter Guide," whose mailers make the same endorsements as Feel the Bern.

Mailed political fliers typically identify the organization that paid for the literature. But that information was conspicuously absent from Feel the Bern and the other two mailers...

The measure would allow ride-hail and delivery drivers to continue to be treated as independent contractors, although with some new benefit concessions. If it fails, these employees would likely be considered workers entitled to a minimum wage, overtime pay, workers' compensation, unemployment insurance and paid sick leave.

The California Democratic Party has endorsed a "no" vote for Prop. 22.

BishopBerkeley writes: In another first, the editors of the The New England Journal of Medicine (NEJM) endorse Joe Biden by stating that the current government needs to be fired. Although they don't mention any names, the editors of the NEJM state in shockingly forceful and accusatory language that the current administration is totally incompetent and does not deserve to keep its job. The editorial, somberly titled "Dying in a Leadership Vacuum" bases its opinion on some dispiriting statistics:

"The magnitude of this failure is astonishing. According to the Johns Hopkins Center for Systems Science and Engineering, the United States leads the world in Covid-19 cases and in deaths due to the disease, far exceeding the numbers in much larger countries, such as China. The death rate in this country is more than double that of Canada, exceeds that of Japan, a country with a vulnerable and elderly population, by a factor of almost 50, and even dwarfs the rates in lower-middle-income countries, such as Vietnam, by a factor of almost 2000. Covid-19 is an overwhelming challenge, and many factors contribute to its severity. But the one we can control is how we behave. And in the United States we have consistently behaved poorly."

The Administration's extreme rhetoric and extreme actions are earning extreme reactions. Last month, Scientific American broke a 175-year tradition of not endorsing a presidential candidate by throwing their support behind Joe Biden. "We'd love to stay out of politics, but this president has been so anti-science that we can't ignore it," editor in chief, Laura Helmuth told The Washington Post.

The editor in chief of Science Magazine also denounced Trump, but stopped short of endorsing presidential candidate Joe Biden.

Sixty Coinbase employees have accepted a buyout offer after CEO Brian Armstrong announced a controversial new policy curbing political activism inside the company. Armstrong disclosed the figure in a Thursday email to employees. Ars Technica reports: Armstrong announced the new policy last week after a summer when many technology companies faced pressure from their employees to become more outspoken on issues of social justice. "While I think these efforts are well-intentioned, they have the potential to destroy a lot of value at most companies, both by being a distraction, and by creating internal division," Armstrong wrote in a September 27 blog post. "We've seen what internal strife at companies like Google and Facebook can do to productivity. I believe most employees don't want to work in these divisive environments."

Now Armstrong says that 60 employees accepted the package. Armstrong says that's about 5 percent of the company's headcount. A few more employees are still in discussions with the company and may accept it in the coming days. "For those of you who have decided to move on, I want to thank you for your contributions to Coinbase and we wish you the very best," Armstrong wrote. "And for those of you who are opting in to the next chapter, I want to thank you for your trust and commitment to this mission." Armstrong said that "people from under-represented groups" at Coinbase did not accept the buyout offer in disproportionate numbers. Armstrong said he was committed to "building a diverse, inclusive environment where everyone feels they belong." And while Coinbase is discouraging most forms of political advocacy, Armstrong acknowledged one exception: that cryptocurrency itself is "inherently political." Armstrong wrote that he is "OK being political about this one particular area because it relates to our mission."

Twitter, risking the ire of its best-known user, President Trump, said on Friday that it would turn off several of its routine features in an attempt to control the spread of misinformation in the final weeks before the presidential election. From a report: The first notable change, Twitter said, will essentially give users a timeout before they can hit the button to retweet a post from another account. A prompt will nudge them to add their own comment or context before sharing the original post. Twitter will also disable the system that suggests posts on the basis of someone's interests and the activity of accounts they follow. In their timelines, users will see only content from accounts they follow and ads. And if users try to share content that Twitter has flagged as false, a notice will warn them that they are about to share inaccurate information.

An anonymous reader quotes a report from The New York Times: On Wednesday, Facebook said it would take more preventive measures to keep political candidates from using it to manipulate the election's outcome and its aftermath. The company now plans to prohibit all political and issue-based advertising after the polls close on Nov. 3 for an undetermined length of time. And it said it would place notifications at the top of the News Feed notifying people that no winner had been decided until a victor was declared by news outlets. "This is shaping up to be a very unique election," Guy Rosen, vice president for integrity at Facebook, said in a call with reporters on Wednesday.

Facebook is doing more to safeguard its platform after introducing measures to reduce election misinformation and interference on its site just last month. At the time, Facebook said it planned to ban new political ads for a contained period -- the week before Election Day -- and would act swiftly against posts that tried to dissuade people from voting. Mr. Zuckerberg also said Facebook would not make any other changes until there was an official election result. But the additional moves underscore the sense of emergency about the election, as the level of contentiousness has risen between Mr. Trump and his opponent, Joseph R. Biden Jr. On Tuesday, to help blunt further political turmoil, Facebook also said it would remove any group, page or Instagram account that openly identified with QAnon, the pro-Trump conspiracy movement. "We believe that we have done more than any other company over the past four years to help secure the integrity of elections," Mr. Rosen said.

The House Judiciary Committee says Amazon, Apple, Facebook and Google are monopolies -- but its new plan to rein in their power won't change anything overnight. Instead, Democratic lawmakers propose to rewrite American antitrust law in order to restructure the U.S.'s most successful and powerful industry over time. From a report: The report is a long pass down the field of the tech industry's unfolding conflicts. It could be game-changing -- but it also might never get completed. The report, which runs more than 450 pages, proposes broad updates to antitrust law, including: limiting companies' ability to compete unfairly against third parties on their own platforms by either requiring online marketplaces to be independently run businesses or establishing rules for how such marketplaces can be organized; blocking online platforms from giving themselves preferential treatment or playing favorites with other content providers; requiring social networks to be interoperable so that people can communicate across platforms and carry their data over from one platform to another; directing antitrust enforcers to assume that an acquisition by a dominant tech firm is anticompetitive unless proven otherwise; and allowing news publishers to team up to negotiate against tech platforms looking to carry their content.

Committee investigators spent 16 months reviewing mountains of emails, memos and other evidence to reach these conclusions about the companies:
Amazon: The internet retail giant achieved its dominant position in part through acquiring competitors; has a monopoly over and mistreats third-party sellers; and has created a conflict of interest through its double role as an operator of its marketplace and also a seller there.
Apple: The report says Apple exerts monopoly power over software distribution to more than half the mobile devices in the U.S. It accuses the company of exploiting rivals by levying commissions and fees and copying apps, and says Apple gives preference to its own apps and services.
Facebook: The social media network has monopoly power in the social networking space, the report finds, and takes a "copy, acquire, kill" approach to would-be rivals such as WhatsApp and Instagram, both of which it bought in the early 2010s.
Google: The search engine has a monopoly in the general online search and search advertising markets, according to the report, maintaining its position through anticompetitive tactics such as undermining vertical search providers and acquiring rivals.

"To put it simply, companies that once were scrappy, underdog startups that challenged the status quo have become the kinds of monopolies we last saw in the era of oil barons and railroad tycoons," write the authors of the report. The other side: The companies all deny that they hold monopoly positions or that their practices and acquisitions violate antitrust law, and argue that the tech industry remains healthily competitive.

AmiMoJo shares a report from NBC News: Facebook said Tuesday that it is banning all QAnon accounts from its platforms, a significant escalation over its previous actions and one of the broadest rules the social media giant has put in place in its history. Facebook said the change is an update on the policy it created in August that initially only removed accounts related to the QAnon conspiracy theory that discussed violence, which resulted in the termination of 1,500 pages, groups and profiles.

A company spokesperson said the enforcement, which started Tuesday, will "bring to parity what we've been doing on other pieces of policy with regard to militarized social movements," such as militia and terror groups that repeatedly call for violence. "Starting today, we will remove Facebook Pages, Groups and Instagram accounts for representing QAnon. We're starting to enforce this updated policy today and are removing content accordingly, but this work will take time and will continue in the coming days and weeks," Facebook wrote in a press release. "Our Dangerous Organizations Operations team will continue to enforce this policy and proactively detect content for removal instead of relying on user reports."

Facebook on Tuesday removed a post from President Trump in which he falsely claimed that Covid-19 is less deadly than the seasonal flu. From a report: Facebook spokesperson Andy Stone confirmed the company removed the post for breaking its rules on Covid-19 misinformation. President Trump has, by his own admission, played down the threat of Covid-19. Now, while battling his own bout of the disease, he has continued to dishonestly downplay the severity of the virus. His post on Tuesday falsely equated Covid-19 to the seasonal flu. Twitter has shielded the post with a label and is preventing users from retweeting the post.

The Trump administration is pressuring Senate Republicans to ratchet up scrutiny of social media companies it sees as biased against conservatives in the run-up to the November election, Politico reported Thursday, citing people familiar with the conversations say. And the effort appears to be paying off. From the report: In recent weeks, the White House has pressed Senate Republican leaders on key committees to hold public hearings on the law that protects Facebook, Twitter and other internet companies from lawsuits over how they treat user posts, three Senate staffers told POLITICO. They requested anonymity to discuss private communications. And action is following. Senate Commerce Chair Roger Wicker held a vote in his committee Thursday to issue subpoenas to the CEOs of Facebook, Twitter and Google to testify about how they police content on their platforms. That's after Democrats initially prevented the Mississippi Republican from pushing through subpoenas that could have compelled the CEOs to testify with only a few days' notice.

Senate Judiciary Chair Lindsey Graham (R-S.C.), meanwhile, last week introduced new legislation to address alleged bias on social media and the same day scheduled a markup of the bill for Thursday -- a move that would have made it the fastest any bill on tech's liability protections has moved from introduction to a markup on Capitol Hill in recent memory. Graham announced Thursday that consideration of the measure had been tabled. Both committees are targeting liability protections that have been credited with fueling Silicon Valley's success. The provision -- enshrined in a 1996 law known as Section 230 -- has allowed online businesses to grow without fear of lawsuits over user posts or their decisions to remove or otherwise moderate users' content.

An anonymous reader quotes a report from The Verge: Facebook will ban ads that wrongly claim victory in the US presidential race. The news comes a week after the company announced it would reject ads from Donald Trump or Joe Biden claiming a premature win on November 3rd. The policy covers ads that claim legal forms of voting -- like voting by mail -- will corrupt the outcome of the election. It also bans ads that claim rampant voter fraud could alter the results of the election.

This is a real concern for the 2020 race. Due to mail-in voting, the electoral process is expected to take longer than in years past, and the official results likely won't be announced on November 3rd. Experts worry that because more Democrats are expected to vote by mail than Republicans, Trump could declare an early victory, then sow doubt about the results as more Biden votes trickle in.

AmiMoJo writes: Americans exercise their right to vote from all over the world, and for November's election, few ballots will have traveled as far as those cast by NASA astronauts living and working aboard the International Space Station. During earlier days of human spaceflight, astronauts would only visit space for days, or maybe weeks, at a time. Today, astronauts typically stay in space for six-month missions on the space station, increasing the odds of a spacefarer off the planet during an election. So how does one vote from space? Like other forms of absentee voting, voting from space starts with a Federal Postcard Application, or FPCA. It's the same form military members and their families fill out while serving outside of the U.S. By completing it ahead of their launch, space station crew members signal their intent to participate in an election from space. Because astronauts move to Houston for their training, most opt to vote as Texas residents. Of course, NASA's astronauts come from all over, so those wishing to vote as residents of their home states can work with their counties to make special arrangements to vote from space.

Once their FPCA is approved, the astronaut is almost ready to vote. Like many great things in space, voting starts with an experiment. The county clerk who manages elections in the astronaut's home county sends a test ballot to a team at NASA's Johnson Space Center in Houston. Then they use a space station training computer to test whether they're able to fill it out and send it back to the county clerk. After a successful test, a secure electronic ballot generated by the Clerk's office of Harris County and surrounding counties in Texas, is uplinked by Johnson's Mission Control Center to the voting crew member. An e-mail with crew member-specific credentials is sent from the County Clerk to the astronaut. These credentials allow the crew member to access the secure ballot. The astronaut will then cast their vote, and the secure, completed ballot is downlinked and delivered back to the County Clerk's Office by e-mail to be officially recorded. The clerk has their own password to ensure they are the only one who can open the ballot. It's a quick process, and the astronaut must be sure to submit it by 7 p.m. local time on Election Day if voting as a Texas resident.

Will astronauts vote in this election? Expedition 63/64 crew member Kate Rubins is assigned to a six-month mission launching Oct. 14, and will vote from space. It won't be her first time -- Rubins also cast her vote from the International Space Station during the 2016 election. With a SpaceX Crew Dragon scheduled to carry three additional U.S. crew members to the space station on Oct. 31 as part of the Crew-1 mission, Mike Hopkins, Victor Glover and Shannon Walker will make it to the space station just in time to cast their ballots there, as well. All three have filled out the paperwork and are ready to do so.

On the eve of the first presidential debate, the Biden campaign is pressing Facebook to remove posts by President Trump -- and slamming the social media company as "the nation's foremost propagator of disinformation about the voting process." From a report: By publicly escalating the conflict, the campaign is pressing Facebook to enforce its policies against misinformation more aggressively. "Rather than seeing progress, we have seen regression," campaign manager Jen O'Malley Dillon wrote to Facebook CEO Mark Zuckerberg in a three-page letter obtained by Axios. "Facebook's continued promise of future action is serving as nothing more than an excuse for inaction," the letter says. "We will be calling out those failures as they occur over the coming 36 days."

A Texas company that sells software that cities and states use to display results on election night was hit by ransomware last week, the latest of nearly a thousand such attacks over the past year against small towns, big cities and the contractors who run their voting systems. From a report: Many of the attacks are conducted by Russian criminal groups, some with shady ties to President Vladimir V. Putin's intelligence services. But the attack on Tyler Technologies, which continued on Friday night with efforts by outsiders to log into its clients' systems around the country, was particularly rattling less than 40 days before the election. While Tyler does not actually tally votes, it is used by election officials to aggregate and report them in at least 20 places around the country -- making it exactly the kind of soft target that the Department of Homeland Security, the F.B.I. and United States Cyber Command worry could be struck by anyone trying to sow chaos and uncertainty on election night.

Tyler would not describe the attack in detail. It initially appeared to be an ordinary ransomware attack, in which data is made inaccessible unless the victim pays the ransom, usually in harder-to-trace cryptocurrencies. But then some of Tyler's clients -- the company would not say which ones -- saw outsiders trying to gain access to their systems on Friday night, raising fears that the attackers might be out for something more than just a quick profit. That has been the fear haunting federal officials for a year now: that in the days leading up to the election, or in its aftermath, ransomware groups will try to freeze voter registration data, election poll books or the computer systems of the secretaries of the state who certify election results. With only 37 days before the election, federal investigators still do not have a clear picture of whether the ransomware attacks clobbering American networks are purely criminal acts, seeking a quick payday, or Trojan horses for more nefarious Russian interference. But they have not had much success in stopping them. In just the first two weeks of September, another seven American government entities have been hit with ransomware and their data stolen. "The chance of a local government not being hit while attempting to manage the upcoming and already ridiculously messy election would seem to be very slim," said Brett Callow, a threat analyst at Emsisoft, a security firm.

Google informed its advertisers Friday that it will broadly block election ads after polls close Nov. 3, according to an email obtained by Axios. From a report: Big Tech platforms have been under pressure to address how their ad policies will handle conflicts over the presidential election's outcome. Facebook recently said that it will no longer accept new political ads for the week leading up to Election Day, but it will not block election ads after the polls close. It will, however, reject ads from U.S. political campaigns prematurely claiming victory before results have been declared, per Fast Company. In the email, Google says that advertisers will not be able to run ads "referencing candidates, the election, or its outcome, given that an unprecedented amount of votes will be counted after election day this year." The policy, which is intended to block all ads related to the election, will apply to all ads running through Google's ad-serving platforms, including Google Ads, DV360, YouTube, and AdX Authorized Buyer.

Last week, voters and election administrators who emailed Leanne Jackson, the clerk of rural Hamilton County in central Texas, received bureaucratic-looking replies. "Re: official precinct results," one subject line read. The text supplied passwords for an attached file. But Jackson didn't send the messages. From a report: Instead, they came from Sri Lankan and Congolese email addresses, and they cleverly hid malicious software inside a Microsoft Word attachment. By the time Jackson learned about the forgery, it was too late. Hackers continued to fire off look-alike replies. Jackson's three-person office, already grappling with the coronavirus pandemic, ground to a near standstill. "I've only sent three emails today, and they were emails I absolutely had to send," Jackson said Friday. "I'm scared to" send more, she said, for fear of spreading the malware. The previously unreported attack on Hamilton illustrates an overlooked security weakness that could hamper the November election: the vulnerability of email systems in county offices that handle the voting process from registration to casting and counting ballots. Although experts have repeatedly warned state and local officials to follow best practices for computer security, numerous smaller locales like Hamilton appear to have taken few precautionary measures.

U.S. Department of Homeland Security officials have helped local governments in recent years to bolster their infrastructure, following Russian hacking attempts during the last presidential election. But desktop computers used each day in small rural counties to send routine emails, compose official documents or analyze spreadsheets can be easier targets, in part because those jurisdictions may not have the resources or know-how to update systems or afford security professionals familiar with the latest practices. A ProPublica review of municipal government email systems in swing states found that dozens of them relied on homebrew setups or didn't follow industry standards. Those protocols include encryption to ensure email passwords are secure and measures that confirm that people sending emails are who they purport to be. At least a dozen counties in battleground states didn't use cloud-hosted email from firms like Google or Microsoft. While not a cure-all, such services improve protections against email hacks.

mabu writes: National Voter Registration Day, earmarked to call attention to encouraging more people to register to vote, is a pinnacle of many state's voter registration drives. Unfortunately in the state of Louisiana, its secretary of state Kyle Ardoin, decided this was a great time to shut the web site down for "scheduled maintenance." As a result, people who tried to register to vote online, on one of the most visible days of the registration drive, were denied the ability. "Ardoin's apparent decision to shut down the website raises concerns about ongoing efforts to suppress voter turnout during a heated election season in the midst of the COVID-19 pandemic," reports NOLA.com. New Orleans' mayor Latoya Cantrell called the move "Unacceptable."

"Ardoin, a Republican, has sparred with Democrat Gov. John Bel Edwards over absentee voting -- both in federal court and in the court of public opinion," NOLA.com adds. "A federal judge in Baton Rouge recently overturned efforts by Ardoin and GOP lawmakers to roll back previously expanded absentee voting in Louisiana. The judge's ruling, if it stands, would allow Louisiana voters to cast absentee ballots if they are concerned about COVID-related health risks associated with voting in-person. The ruling effectively reinstates the absentee voting rules that applied to the statewide primaries held in July and August, which came off without a whiff of 'voter fraud.'"