In an affidavit filed in September, Spoonamore asserted that "any time all information is directed to a single computer for consolidation, it is possible… that single computer will exploit the information for some purpose. ... In the case of Ohio 2004, the only purpose I can conceive for sending all county vote tabulations to a GOP managed Man-in-the-Middle site in Chattanooga before sending the results onward to the Sec. of State, would be to hack the vote at the MIM."