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26 It notes that one of plaintiffs’ experts, Dr. Duchin, used an algorithm to create “2 million districting plans for Alabama … without taking race into account in any way in the generation process.” 2 App. 710. Of these two million “race-blind” plans, none contained two majority-black districts while many plans did not contain any. Ibid. Alabama also points to a “race-neutral” computer simulation conducted by another one of plaintiffs’ experts, Dr. Kosuke Imai, which produced 30,000 potential maps. Brief for Alabama 55. As with Dr. Duchin’s maps, none of the maps that Dr. Imai created contained two majority-black districts. See 2 App. 571–572. Alabama thus contends that because HB1 sufficiently “resembles” the “race-neutral” maps created by Dr. Duchin and Dr. Imai—all of the maps lack two majority-black districts—HB1 does not violate §2. Brief for Alabama 54.

Alabama’s reliance on the maps created by Dr. Duchin and Dr. Imai is misplaced. For one, neither Duchin’s nor Imai’s maps accurately represented the districting process in Alabama. Dr. Duchin’s maps were based on old census data—from 2010 instead of 2020—and ignored certain traditional districting criteria, such as keeping together communities of interest, political subdivisions, or municipalities. And Dr. Imai’s 30,000 maps failed to incorporate Alabama’s own districting guidelines, including keeping together communities of interest and preserving municipal boundaries. See Supp. App. 58–59.