This database optimization occured prior to the Lottery selection and is a standard data storage protocol used by Oracle brand database software.It had nothing to do with the fact that this particular database contained DV Lottery entries. This year, the State Department used a new computer program intended to randomly renumber the DV Lottery petitions. The programmer who wrote the program, however, made an error that essentially rendered the program ineffective.
This backfill process - which I referred to in my July 6 declaration as "internal storage optimization algorithms" (Decl.Finally, the database program recorded the petitions with a rule or method designed to optimize data storage and retrieval and to minimize the empty portions of the drives that were interspersed with portions containing data.I declare under penalty of perjury that the foregoind is true and correct.Instead of instructing the computer to select DV Lottery winners based on the rank ordering of the Randomizer Program in step two, the computer program simply selected entries in the order in which the database program stored petitions on the hard drives in step one.Thus, the Randomizer program, which was designed to make the selection random, failed entirely to achieve that goal. I understand the Court has inquired about the State Department's interpretation and definition of "random" that appears in relevant DV Lottery statutes and regulations, including 22 CFR §42.33(c), which requires that the DV Lottery petitions be "...Also, as required by the DV Lottery program, the database program applied region and country limitations to the selection to ensure no single region or country dominated the selection.These limitations, along with the manner in which the database program stored the petitions on the hard drives, account for the fact that some petitions entered on October 5 and 6 were not selected: there were enough petitions with a lower physical location in the database to satisfy the region and country limitations. At the conclusion of this data storage process (step one), the State Department must initiate a second process in which it rand-orders the petitions again, but this time at random, using computer software designed for this purpose (the "Randomizer program"). Next, the State Department must initiate a third process in which it selects petitions from each world region in their rank order as determined by the Randomizer program as winners of the DV Lottery. This year, the State Department used a new computer program intended to server as the Randomizer program. The programmer who wrote the Randomizer program, however, made an error that rendered the Randomizer program ineffective.The database program stored each petition in a physical location on the hard drive, for the most part in the order in which they were received.However due to the database program and the "storage optimization algorithms" there are some exceptions to the order by which database stored petitions, as I discussed in my July 6 Declaration. Because DV Lottery participants submitted petitions at such a high volume, the database program was not always able to store an incoming petition at the physical location on the hard drive immediately adjacent to the location where it had recorded the immediately preceding petitions.§ 5) - explains how and why the database program recorded the two percent of the petitions submitted after October 5 and 6, 2010, in the sections of the hard drives containing nearly all the petitions submitted on October 5 and 6 2010.The database program was designed to minimize the number of these gaps on the hard drives so it could later access the data more quickly and efficiently. After the database program recorded each petition submitted over the Submission period, the database program rank-ordered each petition in the order they were located on the physical hard drives which, as I noted earlier, generally (but not exclusively) corresponded to the date on which they were submitted.