Comment by Carolyn Coggins (Voting System Test Laboratory)

One of the goals of the new standard is transparency. It does not foster transparency if less accessible terminology is used. Nor does it facilitate the work of the labs or manufacturers in communicating information if a term used through out the document has to be translated over and over again for new users. "Subsumes" is not a universally understood term and should be replace everywhere it is used in the document. “Includes” or “incorporates” are good alternatives.