years later and almost before the very same panel we're here arguing essentially the same issues as we were before the two thousand and twelve general election for they have even compared to the home state laws that were specifically enacted for the purpose of denying african americans the right to vote we respectfully submit that there is nothing to very practical threshold question right is this case moot this is a case which was brought up with respect to the ability of the pla be enrolled to vote for the two thousand and twelve election i don't like ssion is in the rearview mirror and that's coming on the circumstances of change because they have now  to such great lengths in their brief in explaining the procedure history of the case is to show that the reason why that occurred the reason why that is effect on me is because after the last time we were here on the case  remember that for this record the state elections commission completed its procedure of inactivating the voters that did not vote in the last election that is a process that began in february of two thousand a charge of contempt of court because that order is there that order is directed to the and i have a very concerned staff asking everybody should we be reactivating this people or not we have all sorts of planning to do in preparation for the two thousand and sixteen election and there's an order of a federal judge saying that all these people need to be reactivated so as much as i of course would embrace and doing reference the same provision that this court held was notably go to what he what i'm saying is that we need a ruling because the problem that we've had all along is that the this issues of l requires us to do and the policy implications go far beyond they interest of the of the companies in this particular case can i can ask you a question i've forgotten whether this is in the record or not how much is the total in fun in have a funds that puerto rico has received and i had an ongoing it is it is ongoing it is ongoing but it has absolutely no  no relations no relation with the shoe of whether or not a person that has not voted in a generalization come vote without reactivating do you know that the number that i asked for of the amount of funds that puerto rico has received you know the answer to that question i don't have it right now i think that it's important then that the court has a clear understanding of what is at stake procedure described in describing people who have not voted in two consecutive general elections but they would have to see it also to receive notice that they may be removed from the voting  yes because of their the fact that they have a movie two times and that that procedure encourages voter fraud why why do you take that position that that would encourage voter fraud but that  that will go through their houses to reactivate the records it's cus nothing it happens bring them the entire do their intent that or year and there is simply no justification for refusing to comply with this requirement limited record because in a two year old the record is so very high complain pretty much and probably it probably this is a provision that is intended to benefit in the we go to voters i believe that the provisional would be closed on forcible if it depended soley on the attorney general bringing an action on behalf of john doe of boston who was removed from the as electoral commissioner of the new progressive party this morning i'm going to address the issue of whether the district court properly determined that applies to perjury co and that article six point one zero two of the pretty specifically includes perjury co within its definition of state or is another as this honorable court also pointed out never did not include predict on this definition the district court also relied on the fact that the ballot for incorporates by reference the provisions of navarra hava separately sets forth the deactivation requirements in its own language does not simply refer to nara which  does with other provisions in hama but for this provision it sets a poor separately and then says that the reference number is simply to ensure it is in it is interpreted as quote unquote consistent with case the title of the clause that opponents was referring to was computerized listening once and it pertains to the technical procedures for removing from the computer lest the voter that is already determine been determined money respect to federal programs set up for this is purely a fundamental right to vote here the only reason the only company state interest that comes to my mind can you describe and vote for is the office of president commission that's an office that exists only in puerto rico right why isn't it rational to say that congress which has broad powers to set criteria for voting in other federal offices can say that with respect to this office which doesn't exist anywhere else we think the puerto rico should be allowed within very wide limits to make rules because the term federal office is covered by the national  to be a rational decision on the part of congress when you consider that there is only one federal office the puerto rican scrollable to vote for and that federal office is  hybrid office between the federal government but the recall that doesn't exist anywhere else or are the marginal basis review on congressional legislation and whether i think that's a good basis or bad because it certainly seems to me to as to whether you should report to the police or recounts different from american citizens living on the maze and in so far as you have a fundamental right to vote that distinction between the colony and the states cannot be held on lest there election if you prevail on the have a claim as argued by co counsel here counsel for the other parties on your side it is there is there are additional relief that's requested under the procedures basically when when the findings were made with what relief is it that you are asking for that you can only that was asked for in the complaint that you can only obtain if you prevail on th go to a public library that you have for public assistance and it's in that these are forms of relief were requested in your complaint i thought the complaint only requested reinstatement and eligibility to be to vote in the two thousand and twelve explicitly made by this court then up police will continue arguing that those relief exactly what he what mr blodgett just asked all those things that he wants what  bring a test case to see what happened there was no indication that they could not comply with the reactivation requirement none none they received that the main plaintiff in the case received actual notice when she actually came to the