Comment on "Benford's Law and the Detection of Election Fraud"

"Benford's Law and the Detection of Election Fraud" raises doubts about whether a test based on the mean of the second significant digit of vote counts equals 4.187 is useful as a test for the occurrence of election fraud. The paper mistakenly associates such a test with Benford's Law, considers a simulation exercise that has no apparent relevance for any actual election, applies the test to inappropriate levels of aggregation, and ignores existing analysis of recent elections in Russia. If tests based on the second significant digit of precinct-level vote counts are diagnostic of election fraud, the tests need to use expectations that take into account the features of ordinary elections, such as strategic actions. Whether the tests are useful for detecting fraud remains an open question, but approaching this question requires an approach more nuanced and tied to careful analysis of real election data than one sees in the discussed paper.