Comment by Kevin Wilson (Voting System Test Laboratory)

As defined in Appendix A, third-party logic could include all of the source code to Windows CE. However, as of the writing of this question, only 3.9 million lines are available for VSTL review. Windows CE is used in a variety of non-voting devices, which provides a strong argument that it is COTS. Perhaps a reasonable compromise is that as in the 2002 version there is trust in the non-modified portions of any COTS software and any modified portions are incorporated into the solution those portions must meet EAC standards and be delivered to the VSTL for review.